Amvel Land Development Corp. v. Absolute Management Corp.

Summary

This consolidated Supreme Court case involved a property dispute where Absolute Management Corp., a creditor of deceased Jose L. Chua, sought to nullify the sale of an Alabang property by the decedent's heirs to Amvel Land Development Corp. The lower courts initially found the heirs acted in bad faith by executing an extrajudicial settlement and selling the property despite pending intestate proceedings, with the Court of Appeals also finding Amvel Land complicit in defrauding creditors. However, the Supreme Court dismissed the case entirely on procedural grounds, ruling that Absolute committed forum shopping by pursuing substantially the same relief in both the civil court (through nullification complaint) and the intestate court (through various motions). The Court emphasized that estate settlement matters must be resolved exclusively within the intestate proceedings under Rule 73, Section 1, and that the probate court has exclusive jurisdiction to authorize or annul estate property dispositions.