CASE DIGEST

ALFREDO HILADO, et al. v. COURT OF APPEALS

G.R. No.

FACTS

Roberto Benedicto died intestate. At the time of his death, there were two
pending civil cases against him involving the petitioners; namely, Alfredo Hilado
and Lopez Sugar Corporation and First Farmers Holding Corporation. His wife,
Julita Benedicto was appointed as the administrator to his estate.

In the list of liabilities that was submitted to the court, Julita included the
amounts of liability of the two pending cases. Petitioners filed with the Regional
Trial Court (RTC) of Manila a Manifestation praying that they be furnished with
copies of all processes and orders pertaining to the intestate proceedings. They
also filed an omnibus motion praying that the Manila RTC set a deadline for the
submission by Julita of the required inventory of the decedent’s estate. Lastly,
they filed other pleadings or motions with the Manila RTC, alleging lapses on the
part of Julita in her administration of the estate, and assailing the inventory that
had been submitted thus far as unverified, incomplete and inaccurate.

Adminstratix Julita opposed the manifestation or motion, disputing the

personality of petitioners to intervene in the intestate proceedings of her
husband. The RTC denied the motion on the ground that the petitioners are not
interested parties within the contemplation of the Rules of Court to intervene in
the intestate proceedings. Later, the Court of Appeals (CA) sided with the RTC in
refusing to allow the petitioners to intervene in the intestate proceedings. The CA
cited the fact that the claims of petitioners against the decedent were in fact
contingent or expectant, as these were still pending litigation in separate
proceedings before other courts. The petitioners appealed to the Supreme Court
citing the Rules on Special Proceedings.

ISSUES

(1) Whether the creditors, whose legal interest is contingent, have the right to
intervene in intestate proceedings under Rule 19 of the Rules of Court.
(2) Whether the petitioners as “interested parties” may be allowed access to
the records of the intestate proceedings.

RULINGS

1
(1) No. Although Section 2 of Rule 72 states that in the absence of special
provisions, the rules provided for in ordinary actions shall be, as far as
practicable, applicable in special proceedings, intervention as set forth under
Rule 19 of the Rules of Court does not extend to creditors of a decedent whose
credit is based on a contingent claim. The definition of intervention under Rule
19 simply does not accommodate contingent claims.

(2) Yes. The petitioners are regarded as interested parties in the intestate estate
of Roberto Benedicto. According to jurisprudence, creditors in a pending case
are considered as interested parties under Rule 135, Sec. 2 of the Rules of
Court. Thus, the petitioners in this case are likewise entitled to notices and
rights as provided for such interested persons in the Rules on Settlement of
Estates of Deceased Persons under the Rules on Special Proceedings. Section 2
of Rule 135 came to fore, the provision stating that the records of every court
of justice shall be public records and shall be available for the inspection of
any interested person.

Allowing creditors, contingent or otherwise, access to the records of the

intestate proceedings is an eminently preferable precedent than mandating
the service of court processes and pleadings upon them. In either case, the
interests of the creditors in the estate are preserved.