SC affirms RTC jurisdiction over wills probated abroad

MANILA, Philippines — The Supreme Court (SC) has clarified the jurisdiction of regional trial courts over wills validated in foreign countries, ruling that RTCs have the authority to handle reprobate proceedings involving foreign probated wills.

This comes in a recent decision penned by Associate Justice Jhosep Lopez, which ordered Branch 17 of the RTC in Cebu City to act on a petition regarding the will of an American citizen with a property in Cebu.

The case stemmed from the will of Lynetta Sekiya, an American resident of Honolulu, Hawaii who passed away in 2017, leaving behind land in Cebu City valued at P896,000.

In 2019, the Circuit Court of the First Circuit of Hawaii declared her will valid. Lynetta’s daughter, Allison, subsequently sought to have the will acknowledged in the Philippines by filing a petition in 2022 for its allowance with Branch 11 of the Municipal Trial Court in Cities (MTCC) in Cebu City.

However, the MTCC dismissed the petition, citing that under Rule 77, Section 1 of the Rules of Court, reprobate proceedings fall under the jurisdiction of the RTC, not first-level courts like the MTCC. Reprobate proceedings, as opposed to probate proceedings, involve determining whether a foreign court properly validated a will.

Allison then took her petition to the RTC, which also dismissed it. The RTC argued that Republic Act (RA) 11576, an amendment to the Judiciary Reorganization Act, designated that first-level courts should handle probate cases involving estates valued at P2,000,000 or below, implying the same rule applied to reprobate cases.

The SC, however, overturned the RTC’s decision, emphasizing the distinction between probate and reprobate proceedings. The Court explained that probate proceedings, which determine the validity of a will, are subject to jurisdictional thresholds based on the estate’s value.

First-level courts, including the MTCC, handle estates valued at P2,000,000 or below, while the RTC handles those above the said value.

In contrast, reprobate proceedings – which address whether a foreign court had the proper jurisdiction to probate a will – are the exclusive domain of the RTC, regardless of the estate’s value.

The SC concluded that RA 11576 did not amend Rule 77 concerning reprobate cases and therefore the RTC must take jurisdiction over Allison’s petition.

This decision underscores the distinct legal frameworks governing probate and reprobate cases in the Philippines and affirms the RTC’s exclusive role in handling foreign probated wills.