GR L 7479; (October, 1955) (Digest)
G.R. No. L-7479 October 24, 1955
FELICISIMA PADILLA, petitioner-appellee, vs. JUANA MATELA, respondent-appellant.
FACTS
Felicisima Padilla filed a petition for the summary settlement of the estate of her aunt, Valeriana Padilla, who died intestate. The estate was valued at not more than P6,000. The court appointed the provincial sheriff as administrator. Julia Padilla, a sister and heir of the deceased, opposed the petition, claiming one property had been conveyed to her by the deceased during her lifetime. While this opposition was pending, Julia Padilla sold that property to Diega Matela on December 11, 1950. Separately, some of the heirs sold the same property to Leon Salvacion, and this sale was approved by the court. The sheriff, following a court order, placed Leon Salvacion in possession and ordered occupants to vacate. Juana Matela, occupying the property on behalf of the minor children of the now-deceased Diega Matela, refused to leave. Felicisima Padilla then filed a motion to annul the sale from Julia Padilla to Diega Matela and to include the property in the estate inventory. The court granted these motions despite Juana Matela’s opposition on jurisdictional grounds. Juana Matela appealed directly to the Supreme Court.
ISSUE
Whether the probate court, in summary settlement proceedings, has jurisdiction to annul a deed of sale of a property claimed to be part of the estate and to order its inclusion in the inventory.
RULING
No. The order of the lower court is revoked. The Supreme Court held that a probate court, particularly in summary settlement proceedings, lacks jurisdiction to adjudicate questions of title to property. Such title disputes must be litigated in a separate action. The Court cited the settled rule that questions of title cannot be passed upon in testate or intestate proceedings, a principle especially applicable in summary settlements meant to expedite distribution and minimize expenses. Additionally, the Court noted that the minor heirs of the buyer, Diega Matela, who had an interest in upholding the sale, were not properly represented, as Juana Matela, their grandmother, had not been appointed as their guardian ad litem. This was another reason for the probate court not to entertain the motion for annulment.