Natcher vs. Court of Appeals, 366 SCRA 385 , G.R. No.

133000 October 02, 2001

Facts:

Spouses Graciano and Graciana Esguerra were registered owners of a parcel of land.
Upon the death of Graciana their six children entered in an extrajudicial settlement of Graciana’s
estate. Before Graciano contracted his second marriage to herein petitioner, he first donated his
pieces of properties to his children leaving only enough for himself. That lot which is left for him
was subdivided into two where the first lot was sold to a third person and the second one was
still in his ownership. Then when Graciano married Patricia Natcher, he sold the second lot to
her. Graciano died. Here comes the controversy that rooted from the sale of the second lot by
their father to herein petitioner. The six children of Graciano want that the sale be annulled
because it was through fraud, misrepresentation and forgery that the second lot was sold to
Natcher. The RTC issued a decision, among which is the declaration that the deed of sale
cannot be regarded as donation it may however be regarded as an extension of advance
inheritance of Patricia Natcher being a compulsory heir. CA reversed the decision of RTC.

Issue:
Whether or Not RTC acting on its general jurisdiction could render adjudication and
resolve the issue of advancement of real property

Ruling:

No. RTC is devoid of authority to render adjudication and resolved the issue of
advancement of real property. Matters which involve settlement and distribution of the estate of
the decedent fall within the exclusive province of the probate court in the exercise of its limited
jurisdiction. SC contended that RTC Manila was not properly constituted to be a probate court
when it decides on these matters.
In a train of decisions, SC has consistently enunciated the long standing principle that
although generally a probate court may not decide a question of title or ownership yet if the
interested parties are all heirs, or the question is one of collation or advancement, or the parties
consent to the assumption of jurisdiction by the probate court and the rights of third parties are
not impaired, then the probate court is competent to decide the question of ownership.