FACTS:

This case involves the intestate proceedings of Roberto Benedicto, a sugar magnate who died intestate. His wife, Julita Benedicto, and daughter, Francisca Benedicto-Paulino, survive him. At the time of his death, there were two pending civil cases against Benedicto involving the petitioners. Julita filed a petition for the issuance of letters of administration, which was granted. The petitioners, who are creditors of Benedicto, argue that they have the right to intervene in the proceedings based on certain provisions in the Rules on Special Proceedings. However, it is argued that intervention does not extend to creditors with contingent claims. It is also noted that the claims of the petitioners against Benedicto are based on tort, not contract, and therefore do not fall under the class of claims to be filed under the notice to creditors. The merits of the petitioners' claims are to be settled in the civil cases where they were raised, and not in the intestate proceedings.

ISSUES:

1. To what extent may the claimants participate in the intestate proceedings?

2. Whether or not the petitioners are entitled to be furnished with copies of all processes and orders issued in connection with the intestate proceedings, as well as the pleadings filed by the administrator of the estate.

3. Whether or not the petitioners are entitled to access the records of the intestate proceedings.

4. Whether or not the petitioners are entitled to notice in instances where the Rules on Special Proceedings require notice to interested parties.

5. Whether or not the petitioners are entitled to have a deadline set for the submission of a verified and complete inventory of the estate and the submission of a verified annual account by the administratrix.

6. Is a person with a contingent claim against the estate entitled to compel an administrator to perform the duty of providing an inventory and rendering an account of administration?

7. Who has the authority to seek the removal of an administrator if complaints are made against their general competence?

RULING:

1. The claimants may participate in the intestate proceedings to protect their interests. The court affirmed that claimants with inchoate interests in the estate of the decedent are allowed to intervene in the proceedings to protect their respective interests. The court recognized that the claims of the petitioners were based on tort and were pending in separate civil cases. Civil actions for tort or quasi-delict survive the death of the decedent and may be commenced against the administrator. Therefore, the court held that the merits of the petitioners' claims against the decedent should be settled in the civil cases and not in the intestate proceedings. However, the claimants have the right to enforce any judgment in their favor against the estate. Until such time, they are allowed to participate in the intestate proceedings to protect their interests.

2. Yes. Petitioners are entitled to be furnished with copies of all processes and orders issued in connection with the intestate proceedings, as well as the pleadings filed by the administrator of the estate. This is necessary for the petitioners to be apprised of developments in the proceedings and to protect their interests in the estate.

3. Yes. Petitioners are entitled to access the records of the intestate proceedings. They are considered "interested persons" entitled to access the court records as stated in Rule 135, Section 2 of the Rules of Court. Allowing creditors, contingent or otherwise, access to the records of the intestate proceedings is a preferable precedent than mandating the service of court processes and pleadings upon them.

4. Yes. Petitioners are entitled to notice in instances where the Rules on Special Proceedings require notice to interested parties. They are considered "interested parties" and should receive notice in accordance with the specific instances provided in the Rules.

5. The Court did not provide a ruling on this issue as it was not directly addressed in the case.

6. A person with a contingent claim against the estate is not entitled to compel an administrator to perform the duty of providing an inventory and rendering an account of administration. Rule 83 requires the administrator to return an inventory within three months from appointment, and Rule 85 requires the rendering of an account of administration within one year from receipt of letters testamentary or of administration. There are reliefs available under Rule 88 to protect the interests of those with contingent claims against the estate.

7. Complaints against the general competence of an administrator may be addressed by seeking their removal in accordance with Rule 82. A creditor, even a contingent one, has the personality to seek the removal of an administrator as their interest relates to the preservation of sufficient assets to answer for the debt.

PRINCIPLES:

• Civil actions for tort or quasi-delict survive the death of the decedent and may be commenced against the administrator.

• Persons with inchoate interests in the estate of a decedent are allowed to intervene in the intestate proceedings to protect their respective interests.

• The merits of claims based on tort or quasi-delict should be settled in separate civil cases and not in the intestate proceedings. However, any judgment in favor of the claimants can be enforced against the estate.

• Petitioners may be allowed to seek certain prayers or reliefs from the intestate court not explicitly provided for under the Rules if the prayer or relief sought is necessary to protect their interest in the estate and there is no other modality under the Rules by which such interests can be protected.

• The records of every court of justice shall be public records and shall be available for the inspection of any interested person, as stated in Rule 135, Section 2 of the Rules of Court.

• If the Rules on Special Proceedings require notice to interested parties, the interested parties are entitled to such notice.

• Allowing creditors access to the records of the intestate proceedings is an eminently preferable precedent than mandating the service of court processes and pleadings upon them.

• Rule 83 of the Rules on Settlement of Estates of Deceased Persons requires an administrator to provide an inventory within three months from appointment.

• Rule 85 of the Rules on Settlement of Estates of Deceased Persons requires an administrator to render an account of administration within one year from receipt of letters testamentary or of administration.

• Rule 88 of the Rules on Settlement of Estates of Deceased Persons provides protection for the interests of those with contingent claims against an estate.

• Rule 82 of the Rules on Settlement of Estates of Deceased Persons provides for the removal of an administrator if complaints are made against their general competence.