GR L 69757; (January, 1988) (Digest)
G.R. Nos. L-69757-58, January 29, 1988
CIRCA NILA DEVELOPMENT CORPORATION, TEODORO K. KATIGBAK and JENNIFER EVIDENTE BAERTGES, petitioners, vs. HON. SALVADOR J. BAYLEN, Judge, Regional Trial Court, Branch CXXI, Caloocan City, INTESTATE ESTATE OF SOLEDAD BALATBAT and TESTATE ESTATE OF RICARDO BALATBAT, respondents.
FACTS
The Estates of Soledad and Ricardo Balatbat, under settlement proceedings in the respondent Regional Trial Court (RTC), entered into a “Property Management and Exchange Contract” with petitioners Circa Nila Development Corporation and its representatives. The contract involved developing estate properties for a total consideration of P2,600,000.00. The respondent judge, acting as a probate court, approved this contract on May 9, 1984.
Subsequently, the Estates filed an “Omnibus Motion” in the same probate proceeding, praying that the petitioners be compelled to pay an alleged balance of P456,100.00 under the contract. The petitioners opposed, contending that the probate court lacked jurisdiction to enforce the contractual obligation. Despite this, the respondent judge issued orders on October 18, 1984, and January 23, 1985, directing payment of the balance and an additional sum, prompting this petition.
ISSUE
Whether a Regional Trial Court, sitting as a probate court, has jurisdiction to compel performance under a contract it had previously approved incidental to the estate settlement.
RULING
The Supreme Court ruled for the petitioners, holding that the respondent judge acted without jurisdiction. A probate court is a tribunal of limited jurisdiction. Its primary function is the settlement of the estate of a deceased person, which includes the approval of contracts for the sale or disposition of estate properties as required under Rule 89 of the Rules of Court. However, such approval is merely a prerequisite for the validity of the contract; it does not confer upon the probate court the power to adjudicate the ensuing rights and obligations of the contracting parties.
The enforcement of contractual terms, such as compelling payment of the purchase price, is a matter of specific performance that falls under the general jurisdiction of the Regional Trial Court, not its limited probate jurisdiction. The Court clarified that the petitioners’ participation in formulating and executing the contract did not estop them from challenging jurisdiction, as they never invoked the probate court’s authority to resolve the contractual dispute. The cited case of Pio Barretto Realty Development, Inc. vs. Court of Appeals was distinguished, as it involved enforcing an agreement made directly with the court itself regarding the sale’s terms, not the underlying contract with the estate. Consequently, the assailed orders were declared null and void for having been issued without jurisdiction.