MANILA— The Supreme Court (SC) has upheld a lower court’s order requiring Union Bank of the Philippines (UnionBank) to explain withdrawals from the bank accounts of the late Ignacio T. Arroyo and submit related email exchanges as part of proceedings to settle his estate.

In a decision penned by Associate Justice Henri Jean Paul B. Inting, the SC Third Division ruled that probate courts have the authority to determine provisionally whether assets belong to a deceased person’s estate and require an accounting of such property.

The case stemmed from the discovery by estate administrators Bernardina Arroyo Tantoco and Alicia Rita Arroyo of withdrawals from Arroyo’s UnionBank accounts after his death, which were made without the heirs’ knowledge.

The administrators asked the Regional Trial Court (RTC) to direct the bank to explain the transactions and produce additional records, including email exchanges between bank officers and a certain Atty. Fe.

The RTC granted the request, and the Court of Appeals sustained the order.

UnionBank subsequently challenged the ruling before the SC, arguing that the RTC had exceeded its authority as a probate court. The bank maintained that the withdrawals were made under a survivorship agreement and that some of the funds were used to settle Arroyo’s existing obligations.

It also argued that any effort to recover the money should be pursued through a separate civil case.

The SC rejected the bank’s arguments, explaining that although probate courts exercise limited jurisdiction, they may provisionally determine whether disputed property forms part of an estate.

Under Rule 87 of the Rules of Court, courts handling estate proceedings may also require individuals suspected of concealing or taking estate property to answer questions and account for the assets.

In Arroyo’s case, the SC noted that the bank accounts were admittedly under his name. The RTC’s directive was intended to establish the amount of money in the accounts at the time of his death and determine whether the funds should be included in the estate.

The high court also emphasized that estate administrators are responsible for identifying, accounting for and protecting the deceased’s assets for the benefit of heirs and creditors.

It further clarified that the probate court, rather than the bank, must determine whether funds covered by a survivorship agreement belong to the estate.

UnionBank should not have independently applied Arroyo’s deposits to his alleged debts while bypassing the estate settlement proceedings, the SC said.

Creditors must file their claims before the probate court instead of taking estate assets on their own to satisfy outstanding obligations.