THE PETITION FOR THE ISSUANCE OF LETTERS TESTAMENTARY IS NOT AN INITIATORY PLEADING, BUT A MERE CONTINUATION OF THE ORIGINAL PETITION FOR THE PROBATE OF THE WILL:

     Hence, respondent’s failure to include a certification against forum-shopping in his petition for the issuance of letters testamentary is not a ground for outright dismissal of the said petition. (Nittscher vs. Nittscher, G.R. No. 160530, November 20, 2007, Quisumbing, J.)