Tuesday, March 1, 2016

BRIONES vs. HENSON-CRUZ 563 SCRA 69



FACTS: 

Ruby filed a petition for the allowance of the will of Luz however, Lilia opposed it. The trial court designated Atty. Briones as Special Administrator of the estate. The heirs of Luz filed a Notice of Appeal assailing the order as to the payment of Briones’ commission. They subsequently filed their record on appeal. The trial court denied the appeal and disapproved the record on appeal on the ground of forum shopping. The heirs filed with CA a Petition for certiorari. CA reversed the decision of the trial court for the latter had no power or authority to deny the appeal on the ground of forum shopping. CA also refused to resolve the issue of forum shopping

ISSUE: WON multi- appeals are allowed in the same case.

RULING: 

YES. The rationale behind allowing more than one appeal in the same case is to enable the rest of the case to proceed in the event that a separate and distinct issue is resolved by the court and held to be final. In this multi-appeal mode, the probate court loses jurisdiction only over the subject matter of the appeal but retains jurisdiction over the special proceeding from which the appeal was taken for purposes of further remedies the parties may avail of. Where multi-appeals are allowed, we see no reason why a separate petition for certiorari cannot be allowed on an interlocutory aspect of the case that is separate and distinct as an issue from the aspect of the case that has been adjudged with finality by the lower court. To reiterate, the matter appealed matter was the special administrator's commission, a charge that is effectively a claim against the estate under administration, while the matter covered by the petition for certiorari was the appointment of an auditor who would pass upon the special administrator's final account. By their respective natures, these matters can exist independently of one another and can proceed separately as envisioned by the Rules under Rule 109.

No comments:

Post a Comment