Fernando v. Crisostomo
REITERATIONFacts
The Antecedents: This case concerns the guardianship of the minor children of the deceased spouses Rufino Crisostomo and Petra Fernando, and the administration of their intestate estate. Hermogenes C. Fernando was appointed as the guardian for the minors Rufino Crisostomo, Jr., Juan Crisostomo, Roberto Crisostomo, and Gabriel Crisostomo, overseeing both their persons and properties. Following the death of Rufino Crisostomo Sr., the guardian sought to approve an extra-judicial settlement of the deceased parents' estate. However, this action was opposed, leading to a dispute over the proper administration and distribution of the estate. Procedural History: The proceedings originated in the Court of First Instance of Bulacan, involving two consolidated cases: the guardianship of the Crisostomo minors (G.R. No. L-2963) and the intestate estate of the deceased spouses (G.R. No. L-2964). The guardian, Hermogenes C. Fernando, attempted to secure approval for an extra-judicial settlement, which the court denied, declaring the settlement null and void, citing a prior Supreme Court ruling that a guardian is not an administrator until the estate is adjudicated to the minors. The guardian also filed a contempt petition against German Crisostomo and Victor Dimagiba for allegedly taking possession of the minors' inherited properties, which was also denied. In the intestate proceedings, German Crisostomo and Pacita Fernando were appointed co-administrators, despite the guardian's opposition and motion to dismiss, which was implicitly denied by the court's actions. The Petition: The appellant, Hermogenes C. Fernando, acting as guardian, appealed several orders from the Court of First Instance of Bulacan. These appeals challenged the denial of the extra-judicial settlement, the dismissal of the contempt petition, and the denial of the motion to dismiss the intestate proceedings. The core of the appellant's argument was that the intestate proceedings should not have been opened or should have been dismissed, and that the extra-judicial partition should have been approved. The Supreme Court, however, had previously ruled in related certiorari proceedings (G.R. No. L-2172) that the intestate proceedings were within the court's jurisdiction and that the appointment of administrators was proper, establishing these rulings as res judicata and the law of the case for the current appeal.
Issue(s)
Whether the court should have denied or dismissed the petition for the opening of intestate proceedings. Whether the project of partition submitted by the guardian in the guardianship proceedings should have been approved. Whether German Crisostomo and Victor Dimagiba committed contempt of court.
Ruling
The orders appealed from are affirmed. The Supreme Court ruled that the intestate proceedings were within the jurisdiction of the court and that the appointment of administrators was proper. The extra-judicial settlement was declared null and void as the guardian was not yet the administrator of the estate. The contempt charges were dismissed as the co-administrator acted within his rights.
Ratio Decidendi
On the denial/dismissal of intestate proceedings: The Supreme Court reiterated its ruling in G.R. No. L-2172 that the brothers of the deceased have an interest as next of kin to petition for letters of administration. The court held that the respondent judge acted within his jurisdiction in appointing the administrators. The guardian of the minor children is not, as such, the administrator of the estate of the deceased until and after said estate has been acquired by or adjudicated to the minors by proper proceedings. The Supreme Court emphasized that the resolutions in the certiorari proceedings constitute res judicata and "the law of the case" with regard to the present appeal, thus the claim that the intestate proceedings should be dismissed must be denied. On the approval of the extra-judicial settlement: The Court affirmed the denial of the motion for approval of the extra-judicial settlement. It reiterated the principle that a guardian is not the administrator of the deceased's estate until the properties have been adjudicated to the minors. Since no partition, either judicial or extra-judicial, had yet been made adjudicating the properties to the minors, the properties of the deceased had never been placed under the administration of the guardian of his minor children. Therefore, the extra-judicial settlement executed by the guardian was correctly declared null and void. On the contempt charges: The Supreme Court affirmed the denial of the petition for contempt. The court found that German Crisostomo, in his capacity as co-administrator of the estate, had the right to possess the properties in question. Victor Dimagiba was merely his overseer. Therefore, their actions did not constitute contempt of court as they were acting within the scope of their authority as administrators of the intestate estate.
Main Doctrine
A guardian of minor children is not, as such, the administrator of the estate of the deceased parents until and after said estate has been acquired by or adjudicated to the minors by proper proceedings. The appointment of administrators for an intestate estate is within the jurisdiction of the probate court, and errors in such appointment are correctible by appeal, not certiorari.