G.R. No. L-18799. March 31, 1964.
HON. JOSE F. FERNANDEZ, Judge of the Court of First Instance, Negros Occidental, ASUNCION MARAVILLA, ET AL., petitioners, vs. HERMINIO MARAVILLA, respondent.

FACTS

Herminio Maravilla petitioned for the probate of his deceased wife Digna’s will, naming him universal heir and executor. The deceased’s siblings, Asuncion, Pedro, and Regina Maravilla, opposed probate, alleging the will was not signed on each page in the presence of the witnesses. The probate court initially appointed Herminio as special administrator, reasoning the estate properties were conjugal and registered in his name. Subsequently, the court denied probate of the will due to the cited formal defect. Following this denial, the siblings petitioned for the appointment of Eliezar Lopez as a special co-administrator, asserting their status as legal heirs. The probate court granted this appointment.
Herminio Maravilla then filed a petition for certiorari and prohibition with the Court of Appeals, seeking to annul the order appointing Lopez as special co-administrator. The siblings moved to have the case certified to the Supreme Court, arguing the value of the estate exceeded P200,000 and the Court of Appeals lacked jurisdiction as the writs sought were not in aid of its appellate jurisdiction. The Court of Appeals assumed jurisdiction, granted Herminio’s petition, and set aside the appointment of the special co-administrator. The siblings elevated the case to the Supreme Court via certiorari.

ISSUE

The primary issue is whether the Court of Appeals had jurisdiction over Herminio Maravilla’s petition for certiorari and prohibition concerning the appointment of a special co-administrator.

RULING

The Supreme Court ruled that the Court of Appeals lacked jurisdiction. The legal logic hinges on the value of the estate in controversy. The Court emphasized that the jurisdiction of appellate courts is determined by the value of the property or amount in controversy. Based on the inventory submitted, the estate’s value exceeded P200,000. Under the Judiciary Act of 1948, as amended, the Supreme Court has exclusive appellate jurisdiction over cases where the value in controversy exceeds P200,000. This jurisdictional threshold applies to special proceedings, including probate, where the subject is the entire estate. The fact that the probate court’s decision denying the will was on appeal to the Court of Appeals in a separate case did not alter this, as the certiorari petition challenging the co-administrator appointment was an independent special civil action. Since the value involved placed the matter within the Supreme Court’s exclusive jurisdiction, the Court of Appeals’ decision was set aside for having been rendered without jurisdiction. Consequently, the Supreme Court also addressed the merits, finding the appointment of a special co-administrator unnecessary and improper under the Rules of Court, which provide for temporary special administrators only until a regular appointment is made. The order appointing Lopez was therefore annulled.