Surname of Digest Author, First Name Initial.

| I2023

Camaya v. Patulandon
GR 144915, February 23, 2004
FACTS:
● Rufina Reyes executed a notarized will wherein she devised several of her properties to her
grandson Anselmo Mangulabnan

● During her lifetime, the testatrix herself filed a petition for the probate of her will which was
then admitted to probate.

● But later, the testatrix executed a codicil modifying a paragraph in her will
○ One property previously devised to Anselmo was given to other heirs

● After the death of the testatrix, Anselmo sought the delivery to him of the title to the said lot
by executor Patulandong, son of the testatrix and Respondent herein.
○ However Patulandong refused in view of the codicil which modified the testator’s
will.

● Thus, Anselmo filed an "action for partition" against Patulandong with the RTC

● The trial court rendered a decision approving the partition, without prejudice to the probate
of the codicil in accordance with the Rules of Court

● Patulandong filed before the RTC a petition for probate of the codicil of the testatrix

● However, by virtue of the prior partition case decision, Anselmo caused the cancellation of the
title of the testatrix over the lot and a new one was issued in his name
○ He later sold this lot to the Camayas, Petitioner herein, and a new TCT was issued in
petitioner’s name

● Thereafter, the trial court rendered a decision admitting the codicil to probate
○ Corollarily, it declared the TCT and Deed of Absolute Sale in favor of the Camayas
as NULL AND VOID

● On appeal, the CA affirmed the trial court

● Hence, this Petition for review on certiorari

● Petitioners argue that:

○ Under the law, the probate court has no power, authority, and jurisdiction to declare
null and void the sale and titles of petitioners

1
 Surname of Digest Author, First Name Initial. | I2023

ISSUES + HELD:
1. W/N the probate court exceeded its jurisdiction when it declared null and void the deed of
sale - YES

● Petitioners’ titles cannot, under probate proceedings, be declared null and void.

● Court cited Cuizon v Ramolete where it discussed the limited jurisdiction of a probate
court
○ It 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.
○ And it cannot determine whether they should or should not be included in the
inventory or list of properties to be administered by the administrator.
○ if there is dispute, then the parties have to resort to an ordinary action for a
final determination of the conflicting claims of title because the probate court
cannot do so.

● Thus, in this case, the probate court exceeded its jurisdiction when it declared the
deed of sale and the titles of petitioners null and void, it having had the effect of
depriving them possession and ownership of the property.

● Moreover, following Section 48 of the Property Registry Decree:

○ - A certificate of title shall not be subject to collateral attack.
○ It cannot be altered, modified, or cancelled except in a direct proceeding in
accordance with law,

2. W/N the final judgment in the partition case bars the allowance of the codicil. - NO.
● Petitioners argue that:
○ by allowing the codicil to probate, it amended the final judgment in the
partition case which is not allowed by law

● the Court disagreed.

● 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.

3. W/N Camayas are innocent purchasers – NOT RULED

● The probate court having no authority to rule upon the validity of petitioners’ titles,

2
 Surname of Digest Author, First Name Initial. | I2023

○ 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.

Ruling: Petition is granted in part

The decision allowing the codicil is AFFIRMED, but the declaration as null and void the deed of sale is
SET ASIDE, without prejudice to the right of respondents in an appropriate action.

SO ORDERED

Notes:
 Motion for reconsideration arguments:
○ Anselmo acquired the lot by will and by the subsequent partition
■ the decision has already reached its finality and therefore can no longer be
negated by a questionable codicil.
○ The vendor had a clean title and the vendees had acquired the same by way of sale as
innocent purchaser in good faith and for value