Teodora A. Rioferio v. Court of Appeals

Summary

This case resolves whether heirs may bring suit to recover estate property pending appointment of an administrator. Alfonso Orfinada Jr. died intestate, leaving legitimate family and paramour with children. The paramour's family executed extrajudicial settlement over estate properties and mortgaged them. Legitimate heirs challenged this, but petitioners argued they lacked standing absent appointed administrator. The Supreme Court affirmed that heirs have legal standing to sue for estate property when no administrator has been appointed, based on Article 777 of the Civil Code transmitting succession rights upon death. The Court established three exceptions to the general rule against heirs suing during administration proceedings, including when no administrator exists. This decision protects estate assets from dissipation while administration proceedings are pending and clarifies heirs' procedural rights in succession matters.