G.R. No. L-5063 / February 21, 1911

FELISA and PRESENTACION PEREZ Y MELLIZA, plaintiffs-appellees, vs. CORNELIO MELLIZA, ET AL., defendants-appellants.

FACTS

Plaintiffs Felisa and Presentacion Perez y Melliza filed an action to recover a sum of money from defendant Cornelio Melliza. The debt originated from the plaintiffs’ claimed interest in certain estates of deceased persons, of which the defendant had been either an executor or administrator. However, the complaint specifically prayed for the recovery of an amount that the defendant allegedly admitted to owe the plaintiffs as a result of an extrajudicial partition agreement or settlement of accounts concerning these estates. The defendants appealed, raising issues including the trial court’s lack of jurisdiction and alleged errors in its discretionary rulings during the trial.

ISSUE

1. Whether the trial court had jurisdiction over the action, considering its connection to estates of deceased persons.
2. Whether the trial court committed reversible error in its discretionary rulings on minor procedural matters.

RULING

1. On Jurisdiction: The Supreme Court held that the trial court had jurisdiction. The action was not one of the special proceedings enumerated in Section 377 of the Code of Civil Procedure (such as actions against executors/administrators touching their official duties, for account and settlement by them, for distribution of estates, or for payment of legacies), which must be brought in the province where the will was probated or letters of administration were granted. Instead, the action was an ordinary money claim based on an extrajudicial partition agreement or settlement of accounts. Therefore, the challenge to the trial court’s jurisdiction failed.

2. On Discretionary Rulings: The Court ruled that the trial court’s rulings on minor procedural matters (such as adjournments and postponements) are discretionary under Section 141 of the Code of Civil Procedure and are not subject to exception unless a clear abuse of discretion is shown. No such abuse was demonstrated in this case. The Supreme Court cited consistent precedent declining to interfere with the trial court’s exercise of discretion absent clear abuse.

The Supreme Court also found that the evidence supported the trial court’s factual findings and the plaintiffs’ right to recover the judgment amount. Accordingly, the judgment was AFFIRMED with costs against the appellant.