GR L 29898; (October, 1987) (Digest)
G.R. No. L-29898 October 9, 1987
VICENTA PO, petitioner, vs. RAYMUNDA CAMPANA and FAUSTINO CAMPANA, respondents.
FACTS
Proceedings were instituted for the intestate estate of spouses Iguianon and Mida (Bagobo). The administrator sued to recover possession of estate lands from defendants, including respondents Raymunda and Faustino Campana, who acquired rights from Incol Iguianon and Adsa Iguianon, children of Iguianon by a second wife. The trial court declared the conveyances void, but the Court of Appeals modified this, holding the deeds of assignment valid to the extent of the shares Incol and Adsa would receive in the estate settlement. This judgment became final.
Subsequently, petitioner Vicenta Po, a granddaughter of the spouses, moved to dismiss the special proceeding, alleging the heirs had already extrajudicially settled the estate. The Campanas opposed, asserting their rights as assignees. The Probate Court denied Po’s motion, declared the extrajudicial settlement null and void, and Po appealed via certiorari, claiming grave abuse of discretion.
ISSUE
Whether the Probate Court committed grave abuse of discretion in denying the motion to dismiss and annulling the extrajudicial settlement that excluded the Campanas.
RULING
No. The Supreme Court dismissed the petition. The final and executory judgment of the Court of Appeals was determinative. It conclusively established that the Campanas’ deeds of assignment were valid to the extent of the shares Incol Iguianon and Adsa Iguianon would receive from the estate. This judicial declaration endowed the Campanas with a legal personality to intervene in the intestate proceedings as successors-in-interest to those specific heirs. Consequently, petitioner Vicenta Po is bound by this adjudication.
The legal logic is clear: a final judgment constitutes res judicata and is binding on all parties. Any partition of the estate that excludes the Campanas, who hold validly assigned rights to a portion of the inheritance, is inherently void. The Probate Court’s order, which upheld the Campanas’ rights and invalidated an exclusionary settlement, was therefore correct and in accord with established facts and law. It did not act with grave abuse of discretion but rather enforced a prior final judgment and protected the vested rights of the assignees.