Cunanan v. Amparo
REITERATIONFacts
The Antecedents: Bonifacio Soriano filed a money claim for P880 against the intestate estate of Isaac Cunanan and Candida Joaquin. The administratrix, Rosalina Cunanan, sought authority to negotiate a loan or sell property to pay this and other obligations. The court granted this authority. Procedural History: The administratix later tendered P880 to Soriano, who refused to accept it, claiming the Japanese notes offered had no value. The administratix then prayed that Soriano be ordered to accept the payment, execute a cancellation deed, and return two parcels of land previously conveyed to him. The court ordered Soriano to deposit the P880 with the clerk of court and deliver the property. Soriano was later charged with contempt for failing to return the property, but was found not guilty, with the court granting him the benefit of the doubt due to a misunderstanding of the order. However, the order to deliver the property was reiterated, with the clerk of court directed to release the deposited P880 to Soriano upon proof of delivery of the property. The Petition: Soriano filed a motion for reconsideration, asserting that the title to the lots had been consolidated in his and his wife's names via a deed of sale with a repurchase option, and that a transfer certificate of title had been issued. The respondent Judge Rafael Amparo granted this motion, setting aside the previous order and justifying Soriano's refusal to accept Japanese military notes. The administratix sought review of these orders, alleging grave abuse of discretion and excess of jurisdiction.
Issue(s)
Whether the probate court has jurisdiction to order the delivery of possession of property when the claimant alleges title via a 'pacto de retro' sale. Whether respondent Soriano is estopped from challenging the court's jurisdiction after having invoked it to file his money claim.
Ruling
The petition is granted. The orders of the respondent judge dated August 16 and September 16, 1946, are reversed. Costs are against respondent Bonifacio Soriano.
Ratio Decidendi
On Issue 1: The Court held that the power to order the delivery of the possession of the lots was a mere consequence of the court's power to approve Soriano's money claim. While probate courts generally do not decide issues of title, they may take cognizance of such matters with the consent of the parties, provided third-person interests are not prejudiced. The determination of title is within the general jurisdiction of Courts of First Instance; thus, any objection to a probate court's handling of the matter is purely procedural. Because Soriano himself set the court in motion and suppressed the fact that the land was held under a 'pacto de retro' agreement, he waived any right to object to the court's jurisdiction over the property. The Court concluded that the procedural rules regarding probate jurisdiction involve personal rights that are subject to waiver by the parties involved. On Issue 2: The Court ruled that Soriano was bound by his own petition and the court's prior adjudication, as a party cannot take a position contradictory to their own pleadings. Estoppel applies because Soriano invoked the court's jurisdiction to collect a debt and only challenged that jurisdiction once the value of the currency offered for repayment became disadvantageous to him. Admissions contained in a pleading are conclusive against the pleader, and Soriano could not 'trifle with a court's decision' by accepting or leaving it at his pleasure. Furthermore, the tender of Japanese war notes in 1944 was valid for preserving the right of redemption since they were the only currency in circulation at that time. Requiring payment in Commonwealth currency during the occupation was deemed unjust and not in accordance with the law as it stood during that period.
Main Doctrine
A party who invokes the jurisdiction of the court and fails to disclose material facts, such as the existence of a sale under pacto de retro, cannot later assail the court's jurisdiction or procedure. Furthermore, a party cannot trifle with a court's decision or order which he himself sought, by taking it or leaving it at pleasure, as allegations, statements, or admissions contained in a pleading are conclusively binding against the pleader.