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Natcher Vs CA Digest

The children of Graciano filed a complaint against Natcher claiming she fraudulently acquired Graciano's land through forgery, impairing their legitime. The RTC found the deed of sale invalid but that it may be an advancement of inheritance. The CA reversed, stating the probate court has exclusive jurisdiction over estate settlements. The Supreme Court affirmed, differentiating civil actions from special estate proceedings, and ruled the probate court has exclusive authority to determine questions of alleged advancement made by the deceased.

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65 views

Natcher Vs CA Digest

The children of Graciano filed a complaint against Natcher claiming she fraudulently acquired Graciano's land through forgery, impairing their legitime. The RTC found the deed of sale invalid but that it may be an advancement of inheritance. The CA reversed, stating the probate court has exclusive jurisdiction over estate settlements. The Supreme Court affirmed, differentiating civil actions from special estate proceedings, and ruled the probate court has exclusive authority to determine questions of alleged advancement made by the deceased.

Uploaded by

mario navalez
Copyright
© © All Rights Reserved
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Download as DOCX, PDF, TXT or read online on Scribd
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Patricia NATCHER VS CA

G.R. No. 133000, Oct. 2, 2001


Facts: Graciano Del Rosario is married to Graciana Esguerra, they have 6 children. They are the
owners of a parcel of land with an area of 9,322 SQ in manila. Upon the death of Graciana, Graciano
together with his 6 children entered into a extrajudicial settlement of the said estate, they divided
the said property where a new title was given.

Graciano donated to his children a portion of his interest in the land amounting to 4,949.30 SQ
leaving only 447 SQ registered under his name as covered by a title. Subsequently, his remaining lot
has also been divided and the other portion was sold to a third person.

Graciano married Natcher, during their marriage, Graciano sold his remaining land to Natcher.
Graciano died leaving Natcher and his 6 children as heirs.

The Children of Graciano filed a complaint against Natcher stating that she employed fraud
misrepresentation and forgery, aquired the land by making it appear that Graciano executed a deed
of sale over the said land, in consequence their legitime has been impaired.

RTC: Deed of sale is prohibited by law


DOS is not a valid donation
DOS may however be an extension of advanc inheritance.

CA: RTC do not have jurisdiction, as the PROBATE COURT has exclusive jurisdiction to make a just
and
legal distribution of the estate.

RTC was trying an ordinary action, hence the acts performed should have been in a probate
court.

ISSUE: W/N the RTC, acting as a court of gen. jurisdiction, adjudicate matters relating to the
settlement of the estate of a deceased person PARTICULARLY ON QUESTIONS AS TO ADVANCEMENT
OF PROPERTY MADE BY THE DECEDENT TO ANY OF THE HEIRS?

HELD: THE SC, differentiated Action VS. Special Proceedings. an action for reconveyance and
annulment of title with damages is a civil action, whereas matters relating to settlement of the
estate of a deceased
person such as advancement of property made by the decedent, partake of the nature of a special
proceeding, which concomitantly requires the application of specific rules as provided for in the
Rules of Court.

The matter in this case fall w/in the exclusive jurisdiction of the probate court in the exercise of its
limited jurisdiction.

Under Sec 2, Rule 90 of ROC, QUESTIONS AS TO ADVANCEMENT MADE OR ALLEGED TO HAVE BEEN
MADE BY THE DECEASED TO ANY HEIR MAY BE HEARD AND DETERMINED BY THE COURT HAVING
JURISDICTION OF THE ESTATE PROCEEDINGS.
While it may be true that the Rules used the word MAY it is nevertheless clear that it contemplates a
probate court when it speaks of the court having jurisdiction of the estate proceedings.

RTC acting in its general jurisdiction is devoid of authority to render an adjudication and resolve the
said issue.

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