G.R. No. L-50261 May 31, 1982
IN THE MATTER OF GUARDIANSHIP OF THE MINORS CECILIA, REBECCA, FLORIDA, RAPHAEL, RODOLFO, LUISITO, TEODORO, all surnamed LAVIDES, ALBERTO C. LAVIDES, petitioner, vs. CITY COURT OF LUCENA, Branch I, respondent.

FACTS

Petitioner Alberto Lavides, upon the death of his wife, filed a petition for guardianship over their seven minor children before the respondent City Court of Lucena in 1971. The petition alleged the estate left by the deceased mother had a total value of P35,000.00, or P5,000.00 for each minor’s share. The court initially assumed jurisdiction, appointed Lavides as judicial guardian, and later authorized him to settle the estate extrajudicially and sell shares of stock.
In 1978, while a motion for confirmation of a Deed of Exchange was pending, a new presiding judge reviewed the case. Finding the total undivided estate was valued at P35,000.00, the court dismissed the petition for lack of jurisdiction. It revoked Lavides’s appointment and annulled all prior proceedings, reasoning that the total estate value exceeded the court’s jurisdictional limit under the Rules of Court and the doctrine in Delgado vs. Gamboa.

ISSUE

Whether the respondent City Court correctly dismissed the guardianship petition for lack of jurisdiction based on the total value of the undivided estate (P35,000.00) rather than the individual share of each minor (P5,000.00).

RULING

The Supreme Court ruled that the City Court erred in dismissing the petition. The legal logic hinges on the proper interpretation of Section 1, Rule 92 of the Revised Rules of Court, which governs jurisdiction in guardianship proceedings. This provision grants concurrent jurisdiction to municipal/city courts and Courts of First Instance, except when the value of the property of the minor or incompetent exceeds the jurisdictional limit of the inferior court. The Court clarified that the phrase “property of such minor” refers to the individual estate of each minor under guardianship.
Therefore, when multiple minors are involved, jurisdiction is determined by the value of each minor’s separate property, not the aggregate value of the undivided estate. Here, each minor’s share was P5,000.00, which was within the jurisdictional amount for city courts at the time. The Delgado doctrine was not overruled by the Revised Rules and, in any event, does not conflict with this interpretation, as it also focuses on the property of the minor. Furthermore, the City Court had already exercised jurisdiction for over seven years, granting orders and authorizing acts. Dismissing the case at a late stage would undermine judicial stability and the interests of justice. The orders of dismissal were set aside, and the case was remanded for further proceedings.