FACTS:

Cristina Aguinaldo-Suntay died intestate, leaving behind her spouse, Dr. Federico Suntay, and five grandchildren. The legitimate grandchildren lived with their mother, Isabel Cojuangco, while the illegitimate grandchildren were raised by Federico and Cristina. Emilio I, son of Federico and Cristina, filed a complaint for legal separation against Isabel, which was declared null and void. Federico and Isabel filed a complaint for visitation rights, which were later stopped. Federico adopted his illegitimate grandchildren. Isabel filed a petition for letters of administration over Cristina's estate, which was opposed by Federico.

A dispute arose over the administration of Cristina's estate. Isabel filed a petition for letters of administration, while Federico moved to dismiss the petition. It was established that Isabel and her siblings were legitimate grandchildren and could represent their father, Emilio I, in the estate. Federico nominated his adopted son, Emilio III, as administrator if letters of administration were issued to Federico. Emilio III opposed Isabel's petition and claimed to be better equipped to administer the estate. The trial court appointed Emilio III as the administrator, but the Court of Appeals reversed this decision and appointed Isabel as the administratrix. The Supreme Court ruled for co-administration between Emilio III and Isabel. Isabel appealed, arguing that Emilio III should not have been co-administrator and that she should be the sole administratrix based on her legitimate grandchild status and the order of preference in the Rules of Court.

ISSUES:

1. Whether the factions among the non-compulsory heirs of the decedent should be represented in the management of the decedent's estate.

2. Who should be appointed as the administrator(s) of the estate.

3. Whether the preference for the surviving spouse in the appointment of an administrator of the estate can be set aside.

4. Whether the demonstration of interest in the estate is sufficient to entitle a person to co-administration.

5. Whether the appointment of Emilio III as co-administrator is justified considering the adverse interests and hostility between him and Isabel and the possible prejudice to the estate.

6. Whether Emilio III failed to properly inventory the assets of the estate, in violation of the Rules of Court.

7. Whether Emilio III failed to take action against Federico's settlement of the estate, which excluded the other heirs and adjudicated certain properties to himself.

8. Whether Emilio III deliberately omitted properties in the inventory.

9. Whether Emilio III's actions demonstrate his unsuitability as administrator of the estate.

10. Whether it would be impractical and improbable to appoint Emilio III as co-administrator with Isabel, considering their hostility towards each other.

11. Whether or not the Motion for Reconsideration is granted.

12. Whether or not a bond should be required for the issuance of Letters of Administration.

13. Whether or not the Regional Trial Court, Branch 78, Malolos, Bulacan is directed to settle the estate of decedent Cristina Aguinaldo-Suntay with dispatch.

RULING:

1. Yes, the factions among the non-compulsory heirs should be represented in the management of the decedent's estate. The Supreme Court held that the nearest of kin with a more preponderant interest in the estate should be preferred in the choice of administrator. This is in line with the preference provided in Section 6 of Rule 78. In the case at bar, the legitimate children were considered the nearest of kin and were entitled to preference over the illegitimate children. Thus, the surviving spouse or the legitimate children or both can be appointed as administrators to represent the interests of both factions.

2. The appointment of the administrator(s) is left to the discretion of the court. The court may appoint the surviving spouse or the legitimate children as the administrator(s), depending on the circumstances and the suitability of the parties involved. The court has the authority to designate two or more special co-administrators for a single estate, especially when there are squabbles among the heirs. The court's decision on the appointment of the administrator(s) is based on its sound discretion.

3. The preference for the surviving spouse in the appointment of an administrator of the estate cannot be set aside without valid and sufficient reason.

4. The demonstration of interest in the estate alone is not sufficient to entitle a person to co-administration.

5. The appointment of Emilio III as co-administrator is not justified considering the adverse interests and hostility between him and Isabel and the possible prejudice to the estate.

6. Emilio III did fail to properly inventory the assets of the estate, which is in violation of the Rules of Court.

7. Emilio III failed to take action against Federico's settlement of the estate, which excluded the other heirs and adjudicated certain properties to himself.

8. It was not clarified whether Emilio III deliberately omitted properties in the inventory, which could be proven by his knowledge of their existence.

9. Emilio III's unsuitability as administrator is demonstrated by his failure to make a true and complete inventory, as well as his inaction regarding Federico's exclusion of the other heirs.

10. It would be impractical and improbable to appoint Emilio III as co-administrator with Isabel due to their deep aversion towards each other, which could be detrimental to the estate.

11. The Motion for Reconsideration is partially granted.

12. Letters of Administration over the estate of Cristina Aguinaldo-Suntay shall solely issue to respondent Isabel Cojuangco-Suntay upon payment of a bond to be set by the Regional Trial Court, Branch 78, Malolos, Bulacan, in Special Proceeding Case No. 117-M-95.

13. The Regional Trial Court, Branch 78, Malolos, Bulacan is directed to settle the estate of Cristina Aguinaldo-Suntay with dispatch.

PRINCIPLES:

• The nearest of kin with a more preponderant interest in the estate is preferred in the choice of administrator.

• The court has the authority to designate two or more special co-administrators for a single estate when there are conflicts among the heirs.

• The appointment of the administrator(s) is based on the court's sound discretion, considering the circumstances and the suitability of the parties involved.

• The surviving spouse is preferred over the next of kin in the appointment of an administrator of the estate.

• The order of preference for the issuance of letters of administration must be observed unless there is a valid and sufficient reason to set it aside.

• The appointment of co-administrators may be sanctioned if the estate is large or complex.

• Mere demonstration of interest in the estate does not automatically entitle a person to co-administration.

• Adverse interests and hostility between co-administrators may result in prejudice to the estate and delay its settlement.

• An administrator is expected to faithfully discharge their duties in settling the decedent's estate, including making a true and complete inventory of the assets.

• Interested parties have the right to complain to the court about any concealment, embezzlement, or conveyance of assets of the decedent.

• It is detrimental to the estate to appoint an administrator who has shown an adverse interest or hostility towards other interested parties.

• The issuance of letters of administration is a preliminary order to facilitate the settlement of the estate and does not preclude other remedies to protect the interests of the administrator.

• Section 10 of Rule 85 requires notice of the time and place of the examination and allowance of the Administrator's account to persons interested.

• Section 7(b) of Rule 89 requires the court to give notice to the persons interested before it may hear and grant a petition seeking the disposition or encumbrance of the properties of the estate.

• Section 1, Rule 90 allows any person interested in the estate to petition for an order for the distribution of the residue of the estate.

• Section 2, Rule 82 allows the court to remove or accept the resignation of an executor or administrator if they neglect to perform their duties or become incapable of discharging the trust.

• Article 992 of the Civil Code or the curtain bar rule is inapplicable in resolving the issue of who is better qualified to administer the estate.

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

• No distribution of the estate shall be allowed until the payment of obligations has been made or provided for, unless the distributees give a bond for the payment of said obligations.

• The Special Second Division in Baguio is not a different division created by the Supreme Court, but is part of the same Second Division with a different composition due to the retirement of a Justice.

• The Supreme Court has the power to grant or deny a Motion for Reconsideration.

• The issuance of Letters of Administration may be subject to the payment of a bond.

• Regional Trial Courts have the responsibility to settle estates with dispatch.