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	GR No. 193161 2011-08-22	DIOSDADO S. MANUNGAS v. MARGARITA AVILA LORETO VELASCO JR., J.
The Court has considered an appointment of a special administrator as an interlocutory or preliminary order to the main case for the grant of letters of administration in a testate or intestate proceeding. In Ocampo v. Ocampo,[21] the Court succinctly held, "The appointment or removal of special administrators, being discretionary, is thus interlocutory and may be assailed through a petition for certiorari under Rule 65 of the Rules of Court."