Martir v. Jalandoni
REITERATIONFacts
1. The Antecedents: This case concerns the testate estate of the late Hilarion Martir and Ligoria Martir. The underlying dispute involves the inclusion of certain parcels of land in the inventory of the estates. These parcels were claimed by the spouses Amado P. Jalandoni and Paz Ramos, who asserted ownership through a deed of sale from Hermogenes Martir, one of the heirs. 2. Procedural History: Hermogenes Martir and Angela Martir were initially appointed co-administrators. Following Hermogenes' death, Amado P. Jalandoni succeeded him as co-administrator. Angela Martir submitted an inventory, accounts, and a project of partition. Jalandoni and the Financing Corporation of the Philippines objected to the inventory and accounts. The Court of First Instance overruled these objections and approved the inventory and accounts, prompting an appeal by Jalandoni and his wife. The case was elevated to the Court of Appeals, which then certified it to the Supreme Court due to the value in controversy exceeding P50,000. 3. The Petition: The appellants, Spouses Amado P. Jalandoni and Paz Ramos, assail the approval of both the inventory and the accounts submitted by co-administratrix Angela Martir. However, the Supreme Court limited the scope of the present appeal to the order overruling their objections to the inventory and declaring the sale of certain lots by Hermogenes Martir to Paz Ramos void. The Court noted that the sale, though lacking judicial approval and thus void as a disposal of property in custodia legis, was valid as an assignment of Hermogenes Martir's hereditary interest, subject to the outcome of the administration proceedings. The resolution of issues pertaining to the accounts was deferred pending the final resolution of a motion for reconsideration by the Financing Corporation.
Issue(s)
Whether the sale by Hermogenes Martir of his hereditary interest in the lots to Paz Ramos is void. Whether the probate court has the authority to pass upon the title to property for the purpose of inclusion in the inventory.
Ruling
The order appealed from is affirmed insofar as it approves the inventory submitted by the co-administratrix, with the understanding that the sale made by Hermogenes Martir in favor of appellants shall be deemed a mere assignment of the vendor's interest in the lots covered by the deed of sale, subject to the result of the administration proceedings. Consideration of the order below with respect to the accounts must await the final resolution of the Financing Corporation's motion for reconsideration.
Ratio Decidendi
On the issue of the probate court's authority to pass upon title for inventory purposes: The Supreme Court held that while questions on title to real property cannot be conclusively determined in testate or intestate proceedings, it is established that for the purpose of determining whether or not a given property should be included in the inventory, the probate court may pass upon the title thereto. This determination, however, is not conclusive and is subject to the final decision in a separate action to be instituted between the parties. Therefore, the ruling of the court below in denying the exclusion of the lots from the inventory was found to be in order. On the validity of the sale of hereditary interest: The Supreme Court noted that the deed of sale, Exhibit "G", conveyed merely Hermogenes Martir's rights and interests in the lots, which constituted his share as an heir in the hereditary estate. The Court reiterated the principle that there is no law prohibiting an heir from selling his interests in an inheritance, provided that such sale is subject to the result of the administration proceedings. Citing the case of Cea et al. vs. Court of Appeals et al., the Court held that the sale, considered as a sale of Hermogenes Martir's interest in properties still under administration, is not necessarily void, but it must be held subject to the result of the administration proceedings. The inclusion of the lots in the inventories was deemed proper.
Main Doctrine
A probate court may pass upon the title to property for the purpose of determining its inclusion in the inventory, although such determination is not conclusive and is subject to the final decision in a separate action. An heir's sale of his interest in an inheritance, pending administration, is valid as an assignment of his interest, subject to the results of the administration proceedings.