Camaya v.

Patulandon
FACTS:
On November 17, 1972, Rufina Reyes (testatrix) executed a notarized will wherein
she devised a Lot to her grandson Anselmo Mangulabnan.
During her lifetime, the Rufina herself filed the Petition for the Probate of her Will
before the CFI.
Later, on June 27, 1973, the Rufina executed a codicil modifying her will by devising
the said Lot in favor of her four children Bernardo (the executor), Simplicia,
Huillerma and Juan (all surnamed Patulandong), and her grandson Mangulabnan
Codicil modified the share of Grandson to the extent of 1/5.
Grandson Mangulabnan later sought the delivery to him by executor Patulandong of
the title of Lot, but Patulandong refused to heed the request because of the codicial
which modified the will of the testatrix.
Thus, Grandson Mangulabnan filed an Action for Partition against Patulandong in
the RTC. The court in this partition ordered the partitioning of the property. However,
the court holds that the partition is without prejudice to the probate of the codicil in
accordance with the Rules of Court.
So, by virtue of the decision in partition case, Mangulabnan caused the cancellation
of the title of the testatrix over Lot 288-A, and another TCT was issued in his name.
Mangulabnan later sold to herein petitioners Camayas Lot no. 288-A by a Deed of
Sale, and thus, a TCT was issued under the name of the Camayas.
However, when the decision of the probate court came, admitting the codicil,
it ruled as null and void, Deed of Sale in favor of the Camayas, and the
corresponding TCT issued in their name,
Further, Register of Deeds was ordered to issue instead corresponding certificates of
titles to the aforesaid four children of the testatrix, and her grandson Mangulabnan to
the extent of 1/5 each pursuant to the codicil.
The Camayas and Mangulabnan filed an MR.
Probate court
Denied this.
CA
Affirmed the decision of the probate court.

Thus, the case was brought to the SC via a petition for review on certiorari.
ISSUES:
1.Whether the probate court exceeded its jurisdiction when it declared null and void
and ordered the cancellation of the TCT of Camayas and the deed of sale.
2.Whether the final judgment in partition case bars the allowance of the codicil.
HELD:
1.As to the first issue, the probate court exceeded its jurisdiction when it declared the
deed of sale as null and void, and also as to the cancellation of the TCTs under the
name of the Camayas.
It is well-settled rule that a probate court or one in charge of proceedings whether
testate or intestate cannot adjudicate or determine title to properties claimed to be a
part of the estate and which are equally claimed to belong to outside parties.
All that said court could do as regards said properties is to determine whether they
should not be included in the inventory.
If there is no dispute, well and good; but if there is, then the parties, the
administrator, and the opposing parties have to resort to an ordinary action for final
determination of the conflicting claims of title because the probate court cannot do
so.
Having been apprised of the fact that the property in question was in the possession
of third parties and more important, covered by a transfer certificate of title issued in
the name of such third parties, the respondent court should have denied the motion
of the respondent administrator and excluded the property in question from the
inventory of the property of the estate.
It had no authority to deprive such third persons of their possession and ownership
of the property. The probate court exceeded its jurisdiction when it declared the deed
of sale and the titles of the Camayas as null and void, it having had the effect of
depriving them possession and ownership of the property.
2.As to the second issue, petitioners argue that by allowing the codicil to probate, it
in effect amended the final judgment in the partition case which is not allowed by
law; and that petitioner Camayas are innocent purchasers for value and enjoy the
legal presumption that the transfer was lawful.
Petitioners argument does not persuade.
Though the judgment in the partition case had become final and executory as it was
not appealed, it specifically provided in its dispositive portion that the decision was
without prejudice [to] the probate of the codicil. The rights of the prevailing
parties in said case were thus subject to the outcome of the probate of the codicil.

The probate court being bereft of authority to rule upon the validity of petitioners
titles, there is no longer any necessity to dwell on the merits of petitioners Camayas
claim that they are innocent purchasers for value and enjoy the legal presumption
that the transfer was lawful.
The petition is granted in part. The decision of the probate court allowing the codicil
is affirmed. But, the declaration of the aforesaid Deed of Sale, and the order to
reissue corresponding certificates of titles to the four children of the testratrix, and
her grandson Mangulabnan are set aside, without prejudice to the respondents
ventilation of their right in an appropriate action.