ANCHETA V. GUERSEY-DALAYGON (CIVIL)

A decree of distribution of the estate of the deceased person vests the title to the land of the estate in the distributees, which if erroneous, may be corrected by a timely appeal, Once it becomes final, its binding effect is like any other judgment in rem.

However, in exceptional cases, a final decree of distribution of the estate may be set aside for lack of jurisdiction or fraud. Further, in Ramon v. Ortuzar, the Court ruled that a party interested in a probate proceeding may have a final liquidation set aside when he is left out by reason of circumstances beyond his control or through mistake or inadvertence not imputable to negligence.

Petitioner's failure to proficiently manage the distribution of Audrey's estate according to the terms of her will and as dictated by the applicable law amounted to extrinsic fraud. Hence, the CA decision annulling RTC orders must be upheld.