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Uy Vs Capulong Case Digest

The document summarizes a Supreme Court case from 1993 regarding a probate court's jurisdiction over questions of property ownership. The case involved two parcels of land sold by the late Ambrocio Pingco that were later claimed by his estate. The probate court canceled the titles issued to the buyers, Jose and Rizana Uy. However, the Supreme Court ruled that a probate court does not have the authority to decide questions of property ownership. It can only elicit information about estate property, not determine ownership. To recover claimed estate property from third parties, an independent civil action must be filed in the proper court.

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JESSIE JAMES YAPAO
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263 views

Uy Vs Capulong Case Digest

The document summarizes a Supreme Court case from 1993 regarding a probate court's jurisdiction over questions of property ownership. The case involved two parcels of land sold by the late Ambrocio Pingco that were later claimed by his estate. The probate court canceled the titles issued to the buyers, Jose and Rizana Uy. However, the Supreme Court ruled that a probate court does not have the authority to decide questions of property ownership. It can only elicit information about estate property, not determine ownership. To recover claimed estate property from third parties, an independent civil action must be filed in the proper court.

Uploaded by

JESSIE JAMES YAPAO
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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JESSIE JAMES O.

YAPAO LEGAL ETHICS


JD-IA

UY V.CAPULONG,
221 SCRA 87 APRIL 7,1993

FACTS:

On February1978, two (2) parcels of land belonging to the late Ambrocio C.


Pingco and his wife had been sold to complainants, Jose P. Uy and Rizalina C. Uy
who registered the sale with the Register of Deeds of Manila in February 1989. The
records show that in the petition for settlement of the estate of Ambrocio C. Pingco,
the counsel for the special administratrix filed an urgent motion requesting the court
to direct the Register of Deeds of Valenzuela to "freeze any transaction without the
signature of Herminia Alvos" involving the several properties formerly owned by
Pingco. ROD reported that the titles to the properties subject of the "freeze order;"
were under a deed of absolute sale executed by the spouses Ambrocio C. Pingco
and Paz Ramirez and that, by virtue of the deed of sale, new transfer certificates of
title were issued in the name of complainants Jose P. Uy and Rizalina C. Uy, except
for TCT’s which were registered with ROD Caloocan.

Counsel for the special administratrix then filed with the court an urgent
motion to cancel the titles issued on the grounds that signatures of the vendors in the
deed of sale were forged. Judge Capulong ordered the cancellation of the titles in
the name of complainant Jose P. Uy and the reinstatement of the names of the
spouses Pingco and Ramirez or the issuance of new titles in their name. Sps Uy
elevated the case to the CA, which reversed the decision of the RTC.

ISSUE:

Whether the RTC, acting as probate court has jurisdiction over question of
ownership where property belonging to the estate is claimed by another person?

RULING:

No, a probate court has no authority to decide questions of the ownership of


property, real or personal. Section 6, Rule 87 of the Rules of Court simply provides
that a person who is suspected of having in his possession property belonging to an
estate, may be cited and the court may examine him under oath on the matter. The
only purpose of the examination is to elicit information or to secure evidence from the
JESSIE JAMES O. YAPAO LEGAL ETHICS
JD-IA

persons suspected of having possession or knowledge of the property of the


deceased, or of having concealed, embezzled, or conveyed away any of the property
of the deceased. Said section nowhere gives the court the power to determine the
question of ownership of such property. Furthermore, the declaration of nullity of the
sale of a parcel of land under administration and the consequent cancellation of the
certificate of title issued in favor of the vendee, cannot be obtained through a mere
motion in the probate proceedings over the objection of said vendee over whom the
probate court has no jurisdiction. To recover the property, an independent action
against the vendee must be instituted in the proper court.

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