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IN RE AGUINALDO-SUNTAY ESTATE

FACTS:

The case involves a family dispute over the estate of Cristina Aguinaldo-Suntay. Cristina died intestate in 1990, leaving behind her husband, Federico, and several grandchildren, including petitioner Emilio III and respondent Isabel Cojuangco-Suntay. Cristina and Federico's only son, Emilio I, predeceased them. Emilio I was previously married to Isabel Cojuangco, but their marriage was annulled. Emilio I had two children out of wedlock, Emilio III and Nenita, who were both acknowledged by the spouses Federico and Cristina. After the death of Cristina, Federico adopted Emilio III and Nenita.

Respondent Isabel filed a petition for the issuance of letters of administration in her favor, but Federico opposed the petition and asserted his right to administer the estate. Federico later nominated Emilio III as the administrator of the estate, which led to Emilio III's intervention in the case. Emilio III argued that he and Federico were better equipped to administer and manage the estate.

Emilio III presented evidence of his education and experience, including his degree in management and his previous employment. On November 13, 2000, Federico died during the course of the proceedings.

After considering the testimonies of both parties and the evidence presented, the trial court denied Isabel's petition and appointed Emilio III as the administrator of Cristina's estate. Emilio III was required to file a bond before entering upon the execution of his trust.

Isabel appealed the decision to the Court of Appeals (CA). The CA reversed the RTC decision, revoked the Letters of Administration issued to Emilio III, and appointed Isabel as the administratrix of the estate, subject to her filing a bond.

Emilio III filed a motion for reconsideration which was denied, prompting him to appeal to the Supreme Court. On appeal, Emilio III raised the following issues: 1) Whether Article 992 of the Civil Code applies in the appointment of an administrator; 2) Whether Emilio III, who was reared by the decedent and her spouse since infancy, is barred from being appointed as the administrator of the estate.

The RTC ruled in favor of Emilio III, emphasizing that the decision was based on what is in the best interest of the estate and the wishes of the decedent and her spouse. The RTC also considered the preference given to the surviving spouse under the Rules of Court. The court believed that Emilio III was academically and experientially prepared for the position of administrator and that his nomination was meritorious for the benefit of the estate and its claimants.

Emilio III appealed the CA's decision to the Supreme Court, seeking to be reinstated as the appointed administrator of the estate.

ISSUES:

  1. Whether Emilio III can be appointed as the administrator of the decedent's estate.

  2. Whether the respondent is preferred over Emilio III in the administration of the estate.

  3. Whether the declaration of heirs made by the lower court is premature.

  4. Whether there is a controversy as to who are the lawful heirs of the deceased person or as to the distributive shares to which each person is entitled.

  5. Whether the distribution of the estate can proceed without settling the question of who will administer the properties of the deceased couple.

RULING:

  1. Emilio III can be appointed as the administrator of the decedent's estate. The court considered the wishes of the decedent and the surviving spouse, who both nominated Emilio III for the position. The court also found that Emilio III, a businessman with a track record in management, has an edge in handling the preservation of the estate.

  2. The respondent is not preferred over Emilio III in the administration of the estate. The court held that the appointment of Emilio III was not subject to a suspensive condition and that he is not barred from representing his deceased father in the estate of his legitimate grandmother. The court also ruled that Emilio III's nomination should not be set aside without a valid and justifiable reason.

  3. The court held that the declaration of heirs made by the lower court is premature. The estate had only been judicially opened and the proceeding has not yet reached the stage of distribution of the estate.

  4. The court also found that there is a controversy as to who are the lawful heirs of the deceased person or as to the distributive shares to which each person is entitled. Section 1, Rule 90 of the Rules of Court requires that such controversy be heard and decided as in ordinary cases.

  5. Furthermore, the court ruled that the distribution of the estate cannot proceed without settling the question of who will administer the properties of the deceased couple.

PRINCIPLES:

  • The court gives preference to the wishes and presumed will of the decedent absent a valid and effective will.

  • The iron curtain bar rule, which bars an illegitimate child from inheriting from the legitimate relatives of their father or mother, does not apply when the actual relationship between the parties is akin to that of legitimate relatives.

  • The court considers the interests of the parties and the qualifications of the potential administrator in appointing an administrator for the estate.

  • The order of preference in the appointment of an administrator is provided under Section 6, Rule 78 of the Rules of Court.

  • The selection of an administrator lies in the sound discretion of the trial court.

  • The order of preference for appointment of an administrator is not absolute and depends on the facts and circumstances of the case.

  • Co-administration may be appointed when justice and equity demand that opposing parties or factions be represented in the management of the estates.

  • The declaration of heirs made by the lower court is premature if the estate has only been judicially opened and the proceeding has not yet reached the stage of distribution of the estate.

  • In cases where there is a controversy as to who are the lawful heirs or as to the distributive shares, the controversy should be heard and decided as in ordinary cases.

  • The distribution of the estate cannot proceed without resolving the question of who will administer the properties of the deceased.