Probate court's jurisdiction NOT limited to determination of heirs, shares

Before we address ourselves to the issue of whether or not petitioners Titulo de Propriedad No. 4136 is null and void and of no legal force and effect, it is best that we first determine whether or not the lower court, acting as a probate court, in the petition for letters of administration, committed grave abuse of discretion amounting to lack of jurisdiction in settling the issue of ownership of the San Pedro estate covered by Titulo Propriedad No. 4136. Petitioners-heirs, in G.R No. 106496, on the one hand, contend that the lower court, then CFI, Bulacan, Branch IV, had no jurisdiction as an intestate court, to resolve the question of title or ownership raised by the public respondent Republic of the Philippines, through the Office of the Solicitor General in the intestate proceedings of the estate of Mariano San Pedro y Esteban. The public respondent, on the other hand, invoking its sovereign capacity as parens patriae, argues that petitioners contention is misplaced considering that when the Republic questioned the existence of the estate of Mariano San Pedro y Esteban, the lower court became duty-bound to rule on the genuineness and validity of Titulo de Propriedad 4136 which purportedly covers the said estate, otherwise, the lower court in the intestate proceedings would be mistakenly dealing with properties that are proven to be part of the States patrimony or improperly included as belonging to the estate of the deceased. A probate court's jurisdiction is not limited to the determination of who the heirs are and what shares are due them as regards the estate of a deceased person. Neither is it confined to the issue of the validity of wills. We held in the case of Maningat v. Castillo, that the main function of a probate court is to settle and liquidate the estates of deceased persons either summarily or through the process of administration. Thus, its function necessarily includes the examination of the properties, rights and credits of the deceased so as to rule on whether or not the inventory of the estate properly included them for purposes of distribution of the net assets of the estate of the deceased to the lawful heirs. In the case of Trinidad v. Court of Appeals, we stated, thus: x x x questions of title to any property apparently still belonging to estate of the deceased maybe passed upon in the Probate Court, with the consent of all the parties, without prejudice to third persons x x x. Parenthetically, questions of title pertaining to the determination prima facie of whether certain properties ought to be included or excluded from the inventory and accounting of the estate subject of a petition for letters of administration, as in the intestate proceedings of the estate of the late Mariano San Pedro y Esteban, maybe resolved by the probate court. In view of these disquisitions of this Court, we hold that the lower court did not commit any reversible error when it issued the Order dated November 17, 1978 which set aside Judge Bagasaos decision dated April 25, 1978 and declared Titulo de Propriedad No. 4136 as null and void, consequently excluding all lands covered by the said title from the inventory of the estate of the late Mariano San Pedro y Esteban. [G.R. No. 103727. December 18, 1996]

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