This case involved a dispute over ownership of funds in a joint bank account between the daughter of the deceased, Anita, and the deceased's surviving children (respondents). Although probate courts typically have limited jurisdiction, they may determine ownership questions if all parties with an interest consent or impliedly agree to submit the issue. Here, the ownership of the joint account funds was not included in the inventory of the deceased's estate. However, the respondents impliedly agreed to the probate court's jurisdiction by raising a claim of ownership over the funds. The court ultimately found that Anita solely owned the funds as the joint account co-depositor.
This case involved a dispute over ownership of funds in a joint bank account between the daughter of the deceased, Anita, and the deceased's surviving children (respondents). Although probate courts typically have limited jurisdiction, they may determine ownership questions if all parties with an interest consent or impliedly agree to submit the issue. Here, the ownership of the joint account funds was not included in the inventory of the deceased's estate. However, the respondents impliedly agreed to the probate court's jurisdiction by raising a claim of ownership over the funds. The court ultimately found that Anita solely owned the funds as the joint account co-depositor.
This case involved a dispute over ownership of funds in a joint bank account between the daughter of the deceased, Anita, and the deceased's surviving children (respondents). Although probate courts typically have limited jurisdiction, they may determine ownership questions if all parties with an interest consent or impliedly agree to submit the issue. Here, the ownership of the joint account funds was not included in the inventory of the deceased's estate. However, the respondents impliedly agreed to the probate court's jurisdiction by raising a claim of ownership over the funds. The court ultimately found that Anita solely owned the funds as the joint account co-depositor.
This case involved a dispute over ownership of funds in a joint bank account between the daughter of the deceased, Anita, and the deceased's surviving children (respondents). Although probate courts typically have limited jurisdiction, they may determine ownership questions if all parties with an interest consent or impliedly agree to submit the issue. Here, the ownership of the joint account funds was not included in the inventory of the deceased's estate. However, the respondents impliedly agreed to the probate court's jurisdiction by raising a claim of ownership over the funds. The court ultimately found that Anita solely owned the funds as the joint account co-depositor.
Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
You are on page 1/ 1
In Matter of Intestate Estate Of Reynaldo Guzman funds in the joint account was neither mentioned nor
Rodriguez V. Rolando C. Rodriguez included in the inventory of the intestate estate of the GR No. 230404, Jan 31, 2018 FIRST DIVISION (Tijam, J.:) late Reynaldo. Therefore, respondents impliedly agreed to submit the issue of ownership before the trial court, DOCTRINE: acting as an intestate court, when they raised an The exception to the general rule that while the affirmative relief before it. To reiterate, the exercise of probate court exercises limited jurisdiction, it may settle the trial court of its limited jurisdiction is not jurisdictional, questions relating to ownership when the claimant and all but procedural; hence, waivable. other parties having legal interest in the property consent, expressly or impliedly, to the submission of the question to the probate court for adjudgment.
FACTS: Reynaldo and Ester left several properties to their surviving children (herein respondents). Respondents executed an Extrajudicial Settlement of both deceased spouses. Meanwhile, Anita is a co- depositor in a Joint Account under the name Anita Ong Tan and Reynaldo. BPI sent a letter to Anita and informed her that her joint account with Reynaldo would become dormant if no transaction will be made. As such, Anita decided to withdraw her funds, hence, requiring the latter to submit the extrajudicial settlement of respondents. Anita then approached respondents and asked them to sign a waiver of rights to the said joint account but the latter refused to sign the alleging that the funds in the said joint account belonged to their father. Respondents then submitted documents to BPI for the release of half of the funds deposited in said joint account. BPI withheld the release of the funds because of the conflicting claims between Anita and respondents. Anita then filed settlement of the Intestate Estate of the late Reynaldo.
ISSUE: May the probate court determine issues of ownership in a bank account deposit?
RULING: Yes. The Court finds the ruling of the trial court that Anita is the sole owner of the funds in question proper. Noteworthy is the fact that even if the probing arms of an intestate court is limited, it is equally important to consider the call of the exercise of its power of adjudication especially so when the case calls for the same. The exception to the general rule that while the probate court exercises limited jurisdiction, it may settle questions relating to ownership when the claimant and all other parties having legal interest in the property consent, expressly or impliedly, to the submission of the question to the probate court for adjudgment.
In this case, the Court notes that the parties
submitted to the jurisdiction of the intestate court in settling the issue of the ownership of the joint account. Furthermore, respondents sought affirmative relief from the intestate court. Said affirmative relief is embodied in respondents' claim of ownership over the funds in said joint account to the exclusion of Anita, when in fact said
