G.R. No. L-51291 May 29, 1984
FRANCISCO CUIZON, ROSITA CUIZON, PURIFICATION C. GUIDO married to TEODORO GUIDO, and JUAN ARCHE, petitioners, vs. HON. JOSE R. RAMOLETE, Presiding Judge of the Court of First Instance of Cebu, Branch III, DOMINGO L. ANTIGUA and SEGUNDO ZAMBO, respondents.

FACTS

The property in dispute, salt beds, was originally part of the estate of Marciano Cuizon. In 1971, his daughter Irene Cuizon sold the property to petitioners Francisco, Rosita, and Purificacion Cuizon, reserving a usufruct for herself. The sale was not immediately registered. In 1976, after the issuance of an Original Certificate of Title in Marciano’s name, a Transfer Certificate of Title (TCT No. 10477) was issued to Irene. Upon Irene’s death in 1978, her half-sister Rufina, as sole heir in an extrajudicial settlement, executed a deed confirming and ratifying the 1971 sale to the petitioners. This deed was registered, and a new title (TCT No. 12665) was issued in the petitioners’ names.
Subsequently, respondent Domingo Antigua was appointed administrator of Irene’s estate in intestate proceedings. He included the salt beds in the estate’s inventory, despite the petitioners’ title and possession. Antigua filed a motion in the probate court, which was granted, seeking authority to sell salt harvested from the property and ordering petitioner Juan Arche to deliver the salt and other products to the administrator. This order was enforced, compelling the petitioners to file this certiorari petition.

ISSUE

Whether a probate court has jurisdiction to issue orders affecting the possession and disposition of properties already covered by a Transfer Certificate of Title issued in favor of persons who are not parties to the intestate proceedings.

RULING

No. The Supreme Court granted the petition and set aside the probate court’s order. The Court reiterated the well-settled rule that a probate court, in charge of testate or intestate proceedings, cannot adjudicate title to properties claimed to belong to outside parties. Its authority is limited to a prima facie determination of whether a property should be included in or excluded from the inventory for purposes of administration.
The legal logic is clear: when a property is registered under the Torrens system and title is held by third parties not involved in the estate proceedings, that title carries a presumptive conclusiveness. The probate court must give this title due weight. In the absence of strong, compelling evidence to the contrary presented in an appropriate ordinary action, the holder of the Torrens title should be considered the owner. Here, the petitioners were not only named in TCT No. 12665 but were also in possession of the property. Therefore, the respondent court, upon being apprised of the petitioners’ title, should have denied the administrator’s motion and excluded the property from the inventory. It acted without jurisdiction when it issued the order divesting the petitioners of possession and control.
The Court emphasized that any challenge to the validity of the sale to the petitioners, including allegations of fraud or questions regarding Rufina’s heirship, must be threshed out in a separate civil action for the final determination of title. The probate court exceeded its jurisdiction by issuing the dispositive order against the titled owners, making it unnecessary for the petitioners to first seek relief from the intestate court before filing the certiorari petition. The restraining order was made permanent.