Pablo Utulo vs Leona Pasion Garcia

G.R. No. 45904 – 66 Phil. 302 – Remedial Law – Special Proceedings – Settlement of Estate – Rule 74 – Extrajudicial Settlement – No need for intestate proceedings if decedent died debtless

Sometime in the 1930s, Juan Garcia died leaving behind properties. Juan was survived by his spouse, Leona Garcia, who later petitioned for administratorship over his estate. The same was granted.

Later, one of Juan’s children, Luz Garcia, died. Luz’s only property was her share in the estate of Juan currently under administratorship. Luz’s widower, Pablo Utulo then filed, in the same intestate court, a petition for administratorship not just over the share of Luz but over the entire estate of Juan. Leona opposed the petition on the ground that there is no need for such because Luz died debtless. The intestate court however ruled in favor of Pablo.

ISSUE: Whether or not the intestate court is correct.

HELD: No. The court repeatedly held that when a person dies without leaving pending obligations to be paid, his heirs, whether of age or not, are not bound to submit the property to a judicial administration and the appointment of an administrator are superfluous and unnecessary proceedings.

SIDE ISSUE: One of the reasons why Pablo wanted to be appointed as administrator, at the very least, over the property of his deceased wife was in order for him to have a standing in the intestate proceeding of Juan Garcia, is the argument valid?

No. There is no prohibition for him to appear in the intestate proceeding of Juan Garcia. All he has to prove is that he was the husband of Luz Garcia. That will suffice to prove his interest.

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