G.R. No. L-60575 March 16, 1987
FRANCISCO E. POBRE, petitioner, vs. HON. JUDGE ARSENIO M. GONONG, COURT OF FIRST INSTANCE OF ILOCOS NORTE, BRANCH IV, ILUMINADA P. LLANES AND FELIX G. LLANES, respondents.

FACTS

Petitioner Francisco E. Pobre was appointed regular administrator of the intestate estates of Maxima Pobre de Quianzon and Jovita Pobre. He submitted an inventory of the estate properties. Private respondent Iluminada P. Llanes, a co-heir, opposed the administration and claimed ownership over several parcels within the inventory, alleging they were acquired from Jovita Pobre via sale and donation. The probate court, presided by respondent Judge, issued orders excluding these contested properties from the estate inventory and directing possession and harvest shares be delivered to Llanes. Petitioner filed this certiorari petition, arguing the exclusion orders were issued without a trial on the merits regarding ownership, thereby exceeding the probate court’s jurisdiction and depriving the estate of properties under its administration.

ISSUE

Whether the respondent Judge acted with grave abuse of discretion in issuing the orders excluding properties from the estate inventory and awarding possession to a claimant without a full trial on the conflicting claims of ownership.

RULING

The Supreme Court dismissed the petition. The legal logic is anchored on the proper forum for resolving ownership disputes involving estate properties. The general rule is that a probate court, being a court of limited jurisdiction, cannot definitively adjudicate questions of title to property. Its primary function is to settle the estate, not to resolve ownership conflicts between the estate and third parties. However, an exception exists when all parties claiming the property are heirs of the decedent; they may optionally submit the title question to the probate court for resolution. In this case, private respondent Llanes, instead of opting to have the probate court settle the title, exercised her right to file a separate civil action for quieting of title (Civil Case No. 1128-IV). Consequently, the probate court’s orders, which were interlocutory in nature, merely excluded the properties from administration pending the outcome of that separate action. This was a proper exercise of discretion to prevent a conflict of possession and avoid multiplicity of suits. The resolution of the conflicting claims of ownership, including the validity of the alleged deeds of sale and donation, must be threshed out in the separate civil case, not via a certiorari petition challenging the probate court’s interlocutory orders. Certiorari does not lie to review factual issues or to correct alleged errors in judgment, but only to correct jurisdictional errors or grave abuse of discretion, which was not present here.