Emilio Pacioles v.

Miguela Chuatoco-ChingFacts:
1.Miguelita died intestate. She was survived by her huband (petitioner) and two minor children.2.Emilio
filed a verified petition for the settlement of Miguelita’s estate.3.Miguelita’s mother filed an opposition
to the petition for issuance of letters of administration. That the bulk of the estate is composed of
paraphernal properties. She wishedto be appointed. She also said that she has direct and material
interest in the estate becauseshe gave half of her inherited properties to the deceased on conditio ntaht
they wouldundertake a business endeavor as partners.4.The mother asked that one Emmanuel be
appointed.5.Court appointed Emilio and Emmanuel as joint-administrator.6.No claims were
filed. Thereafter, Emilio filed an inventory.Emmanuel failed to file one.7.Court declared Emilio
and his children as the only compulsoryheirs of the deceased.8.Emilio then petitioned the
court for the payment of estate tax andthe partition and distribution of the estate.9.RTC
denied the petition as to the partition and distribution. CA affirmed.
Issue:
May a trial court, acting as an intestate court, hear and pass upon questions of ownership involving
properties claimed to be part of the decedent’s estate?
Held:
1. General Rule:a.jurisdiction of the trial court either as an intestate or a probate court relates only
tomatters having to do with the settlement of the estate and probate of will of deceasedpersons but
does not extend to the determination of questions of ownership thatarise during the proceedings
.i. The patent rationale for this rule is that such court exercises special and limited jurisdiction.b.A well-
recognized deviation to the rule is the principle that an intestate or a probatecourt may hear and pass
upon questions of ownership when its purpose is todetermine whether or not a property should be
included in the inventoryi.Pastor v. CA1.As a rule, the question of ownership is an extrataneous matter
which theprobate court cannot resolve with finality. Thus, for the purpose of determining whether a
certain property should or should not be included inthe inventory of estate properties, the probate
court may pass upon the titlethereto, but such determination is provisional, not conclusive, and is
subjectto the final decision in a separate action to resolve title2. Reliance to Pastor v. CA

a. The Court of Appeals relied heavily on the above principle in sustaining the jurisdiction of the
intestate court to conduct a hearing on respondent’s claim.
Such relianceis misplaced
.b. Under the said principle, the key consideration is that the purpose of theintestate or probate court in
hearing and passing upon questions of ownership
is merely todetermine whether or not a property should be included in the inventory
. The facts of this case show that such was not the purpose of the intestate court.i.
First
, the inventory was not disputed.1. Respondent could have opposed petitioner’s inventory and
sought the exclusion of thespecific properties which she believed or considered to be hers
. But instead of doing so,she expressly adopted the inventory, taking exception only to the low valuation
placed on thereal estate properties.ii. Second, Emmanuel (respondent’s son) did not file an inventory1.
He could have submitted an inventory, excluding therefrom those propertieswhich respondent
considered to be hers. The fact that he did not endeavor tosubmit one shows that he acquiesced with
petitioner’s inventory.
2.Clearly, the RTC, acting as an intestate court, had overstepped its jurisdiction. Itsproper course should
have been to maintain a hands-off stance on the matter. It iswell- settled in this jurisdiction, sanctioned
and reiterated in a long line of decisions,that when a question arises as to ownership of property alleged
to be a part of theestate of the deceased person, but claimed by some other person to be his
property,not by virtue of any right of inheritance from the deceased but by title adverse to thatof the
deceased and his estate, such question cannot be determined in the course of an intestate or probate
proceedings.
The intestate or probate court has no jurisdiction to adjudicate such contentions, which must be
submitted to thecourt in the exercise of its general jurisdiction as a regional trial court.
a.
Jurisprudence states that:
i. probate court or one in charge of proceedings whether testate or intestate cannot adjudicate or
determine title to properties claimed to be a part of the estateand which are claimed to belong to
outside parties. All that the said court could do as regardssaid properties is to determine whether they
should or should not be included in the inventoryor list of properties to be administered by the
administrator. If there is no dispute, well andgood, but if there is, then the parties, the administrator,
and the opposing parties have toresort to an ordinary action for a final determination of the conflicting
claims of title becausethe probate court cannot do so.3. Hence, respondent’s recourse is to file a
separate action with a court of general jurisdiction. The intestate court is not the appropriate forum for
the resolution of her adverseclaim of ownership over properties ostensibly belonging to Miguelita's
estate.