G.R. No. L-7635 July 25, 1955
TASIANA ONGSINGCO, Guardian of Francisco de Borja, petitioner, vs. HON. BIENVENIDO A. TAN, as Judge of the Court of First Instance of Rizal and JOSE DE BORJA, administrator of the estate of the late Josefa Tangco, respondents.

FACTS

Petitioner Tasiana Ongsingco is the judicial guardian of her husband, Francisco de Borja, who was declared incompetent. Francisco de Borja is the surviving spouse of Josefa Tangco, whose estate is being settled in Special Proceedings No. 7866. Respondent Jose de Borja is the administrator of Josefa Tangco’s estate. Petitioner, as guardian, took possession of two parcels of land in Santa Rosa, Nueva Ecija, claiming they are the separate property of her ward, Francisco de Borja, acquired by inheritance from his father. When petitioner began threshing the palay crop on the lands, respondent administrator filed a motion in the estate proceedings to restrain her, disputing the ownership of the lands. Petitioner opposed, challenging the probate court’s jurisdiction to determine ownership. After failed attempts to agree on the identity of the lands, petitioner filed an action in the Court of First Instance of Nueva Ecija (Civil Case No. 1350) to determine ownership and to restrain the administrator from interfering. That court granted a preliminary injunction. Despite this, the respondent judge in the estate proceedings issued orders on January 29, 1954, and February 18, 1954, prohibiting petitioner from threshing the palay and addressing the identity of the lands.

ISSUE

1. Whether the respondent court, acting as a probate court in the estate proceedings of Josefa Tangco, has jurisdiction to determine the dispute over the ownership of the two parcels of land, which is the subject of a separate action in the Court of First Instance of Nueva Ecija.
2. Whether the respondent court could issue an order that effectively nullified the writ of preliminary injunction issued by the Court of First Instance of Nueva Ecija, a court of concurrent jurisdiction.

RULING

1. No. The Supreme Court held that the respondent court exceeded its jurisdiction. The well-settled rule is that a probate court cannot adjudicate questions of ownership of property claimed by a person under a title adverse to the estate. Such disputes must be resolved in an ordinary action before a court exercising its general jurisdiction. Since the ownership of the lands was squarely raised in the separate action pending in the Court of First Instance of Nueva Ecija, the probate court had no authority to act upon the question, even under the guise of determining the identity of the properties, as this issue is interwoven with ownership.
2. No. The Supreme Court held that the respondent court should not have issued the order. It is a settled rule that no court has the power to interfere by injunction with the judgments or decrees of a court of concurrent or coordinate jurisdiction having equal power to grant the relief sought. The Court of First Instance of Nueva Ecija and the Court of First Instance of Rizal (the respondent court) are coordinate courts. Allowing one to interfere with the other’s orders would lead to confusion and hinder the administration of justice.
The petition for certiorari was granted. The orders of the respondent court dated January 29, 1954, and February 18, 1954, were set aside.