Ethel Grimm Roberts v. Judge Tomas R. Leonidas

Summary

This succession case involved Edward M. Grimm, an American who died in Manila in 1977, leaving two wills and a complex family situation with a second wife and children from two marriages. Despite the existence of valid wills, his daughter from the first marriage filed an intestate proceeding, which resulted in a court-approved partition that ignored the testamentary dispositions. The second wife later filed a separate testate proceeding seeking to probate the wills and annul the intestate partition. The Supreme Court ruled that the testate proceeding was proper, emphasizing that probate of wills is mandatory and that it is anomalous to settle a testate estate through intestate proceedings. The case establishes the principle that when a person dies with valid wills, testate proceedings must be pursued regardless of any pending intestate cases.