G.R. No. L-24584 October 30, 1975
Iluminada de Gala-Sison, as Administratrix of the Intestate Estate of the late Generoso de Gala, petitioner, vs. Hon. Manolo L. Maddela, as Judge of the Court of First Instance of Quezon and Socorro Manalo, respondents.

FACTS

This case involves the administration of the intestate estate of Generoso de Gala. In 1952, the probate court ordered the administratrix, Iluminada de Gala-Sison, to deposit with a bank the sum of P40,998.56 in her possession. This order was affirmed by the Court of Appeals but later modified by the Supreme Court in a 1963 decision. The Supreme Court ruled that the deposit order should apply only to the remaining balance of the original amount after deducting court-approved expenses and authorized allowances or inheritances paid to the heirs. Following this final decision, the respondent judge issued an order for its execution, directing the administratrix to deposit the remainder.
The administratrix filed a manifestation instead of complying, arguing that no deposit was necessary as the fund had been depleted. She claimed deductions for her own unpaid allowance of P22,000, additional administratrix fees, and litigation expenses, none of which had been previously authorized by the court. The respondent judge, in an order dated August 21, 1964, rejected these claims. He found that the Supreme Court’s decision only permitted deductions for items already approved by the court, which these were not. He thus ordered the deposit of P39,240.15. The administratrix’s motion for reconsideration and separate petitions for approval of her claimed allowance and fees were denied in an order dated May 10, 1965.

ISSUE

Whether the respondent judge acted with grave abuse of discretion in ordering the administratrix to deposit the amount of P39,240.15 and in denying her claims for an advance on her inheritance and compensation as administratrix.

RULING

No, the respondent judge did not commit grave abuse of discretion. The Supreme Court held that the orders were a correct execution of its final 1963 decision. The legal logic is anchored on the doctrine of finality of judgment and the specific parameters set by the Supreme Court’s modification. The High Court’s 1963 decision explicitly limited permissible deductions from the deposit amount to “expenses approved by the court and the allowances and inheritances authorized by the court.” The administratrix’s new claims for her allowance, fees, and other expenses were not covered by this language, as they lacked prior court approval. The respondent judge was therefore legally bound to disregard these unapproved claims when computing the depositable balance.
Furthermore, the separate denial of her motions for allowance and fees was proper. These were new applications requiring judicial approval, which the probate court was within its discretion to deny based on the merits and the circumstances of the estate administration. A writ of certiorari only lies for a capricious and whimsical exercise of judgment equivalent to lack of jurisdiction. The respondent judge’s orders were a logical and faithful implementation of the Supreme Court’s final directive, not an arbitrary act. Consequently, the petition was dismissed for lack of merit.