Probate courts may require banks to explain withdrawals from a deceased person's accounts to determine whether the funds belong to the estate, according to the the Supreme Court (SC).
In a decision made public on Friday, Oct. 9, the SC Third Division upheld a Regional Trial Court (RTC) order directing the Union Bank of the Philippines (UnionBank) to explain withdrawals from the accounts of the late former Negros Occidental Rep. Ignacio “Iggy” Arroyo and submit related email exchanges.
The ruling stemmed from estate settlement proceedings initiated by administrators Bernardina Arroyo Tantoco and Alicia Rita Arroyo, who discovered that funds had been withdrawn from Arroyo’s accounts after his death without the heirs’ knowledge, written by Associate Justice Henri Jean Paul B. Inting and promulgated on July 7, 2026.
"UnionBank challenged the ruling before the SC, arguing that the RTC had exceeded its authority as a probate court," the ruling said.
The bank maintained that the withdrawals were made under a survivorship agreement and that the funds were used, among other things, to settle Arroyo’s existing obligations. It also argued that efforts to recover the money should be pursued through a separate civil case.
The court rejected the bank’s arguments, explaining that although probate courts have limited jurisdiction, they may provisionally determine whether property belongs to a deceased person’s estate.
Under Rule 87 of the Rules of Court, probate courts may require individuals suspected of concealing or taking estate property to answer questions and account for the assets.
In this case, the RTC sought to establish the amount in Arroyo’s accounts at the time of his death and determine whether the funds should form part of his estate. The SC also affirmed the administrators’ authority to identify, account for and protect the deceased’s assets for the benefit of heirs and creditors.
The high court stressed that the probate court, not the bank, must determine whether funds covered by a survivorship agreement belong to the estate. UnionBank should not have applied Arroyo’s deposits to his alleged debts without going through the estate settlement process.
The SC added that creditors must file their claims before the probate court rather than independently take estate assets to settle their claims.
