G.R. No. L-74; December 8, 1945
Mateo Maniñgat and the spouses Eugenio Pantoja and Leona Baltazar, petitioners, vs. Modesto Castillo and Iñigo S. Daza, Judges of Court of First Instance, and Sixto de Jesus, respondents.

FACTS

In Special Proceeding No. 3174 for the settlement of the estate of Gavino de Jesus in the Court of First Instance of Batangas, petitioners Mateo Maniñgat and the spouses Eugenio Pantoja and Leona Baltazar purchased the hereditary interests of heirs Demetrio, Elena, and Maria de Jesus. They filed motions in the probate court seeking approval of the sales and their subrogation to the rights of the vendor-heirs. Respondent Sixto de Jesus, an administrator and co-heir of the estate, opposed the motions. He argued that the lands sold were mortgaged to the Philippine National Bank with court approval and were subject to other allowed claims. By way of a countermotion, Sixto de Jesus invoked Article 1067 of the Civil Code, praying that if the sales were approved, the petitioners be ordered to resell and convey the purchased interests to him, as a co-heir, upon reimbursement of the purchase price. The petitioners opposed the countermotion, contending that Sixto de Jesus did not make his offer to repurchase within the one-month period prescribed by Article 1067. After a hearing, respondent Judge Modesto Castillo found the offer was timely and granted the countermotion, ordering the petitioners to resell the interests to Sixto de Jesus. A motion for reconsideration was later denied by respondent Judge Iñigo S. Daza on the ground that Judge Castillo’s order had become final. The petitioners then filed this petition for certiorari and mandamus to annul the order and compel the probate court to approve their motions for subrogation, alleging that the probate court lacked jurisdiction to entertain the countermotion under Article 1067, and that such a claim should be filed in a separate ordinary action.

ISSUE

Whether the probate court, in the exercise of its jurisdiction over the settlement of a decedent’s estate, has the authority to entertain and decide a co-heir’s countermotion for subrogation under Article 1067 of the Civil Code, arising from the sale of hereditary rights by another heir during the pendency of the administration proceedings.

RULING

The Supreme Court ruled that the probate court has jurisdiction. The Court held that the primary function of a probate court is to settle and liquidate the estates of deceased persons. As part of this function, it is incumbent upon the court to determine the heirs entitled to the net assets and their respective shares. In this case, conflicting claims over the same hereditary interests were presented to the court by strangers (the petitioners as purchasers) and a co-heir (the respondent) while the estate was still under administration. Adjudicating these conflicting claims according to law, including the application of Article 1067 of the Civil Code, was a necessary part of settling the estate. The Court noted that the petitioners themselves had invoked the probate court’s authority to approve their subrogation, recognizing the property was under court administration. Therefore, the probate court acted within its jurisdiction in issuing the order. The Supreme Court affirmed the order of the probate court and denied the petition.