Short answer. Yes. When a marriage is dissolved by the death of one spouse, Rule 73, Section 2 of the Rules of Court directs that the community property is inventoried, administered and liquidated, and its debts paid, in the testate or intestate proceeding of the deceased spouse — not in a separate liquidation case.
What the law says
When the marriage is dissolved by the death of the husband or wife, the community property shall be inventoried, administered, and liquidated, and the debts thereof paid, in the testate or intestate proceedings of the deceased spouse.
Rule 73, Section 2 — Where estate settled upon dissolution of marriage. Read the full provision →
What the law says
If both spouses have died, the conjugal partnership shall be liquidated in the testate or intestate proceedings of either.
Rule 73, Section 2 — Where estate settled upon dissolution of marriage. Read the full provision →
One proceeding, not two
Rule 73, Section 2 provides that the community property shall be inventoried, administered, and liquidated, and the debts thereof paid, in the testate or intestate proceedings of the deceased spouse. The rule folds the winding-up of the marital property regime into the estate case itself. There is no need to open a second, separate action just to liquidate the absolute community or the conjugal partnership; the court settling the estate handles both tasks in the one proceeding, from inventory through liquidation to distribution.
Why liquidation comes before distribution
Liquidation is what separates the surviving spouse's share in the marital property from the portion that actually belongs to the estate. Until the community or partnership is inventoried and its obligations settled, nobody can say which specific assets pass to the heirs and which remain the surviving spouse's own. That is why the rule pairs liquidation with payment of the debts thereof: obligations chargeable to the marital property are dealt with at this stage, before the net remainder is divided. Heirs who skip the step and divide property as though everything belonged to the deceased routinely end up with wrongly computed shares.
If both spouses have died
The same section answers the situation where the second spouse also dies before the property is wound up: If both spouses have died, the conjugal partnership shall be liquidated in the testate or intestate proceedings of either. The heirs need not maintain two parallel liquidations covering the same pool of property; the settlement court in either spouse's estate can take up the task. This avoids conflicting inventories and lets a single court determine what flows into each estate before anything is distributed.
What this means for the surviving spouse
If you are the surviving spouse, expect the marital property — including assets held in your own name that form part of the community or partnership — to appear in the estate inventory, because the proceeding must account for the whole mass before it can liquidate it. Your share is not an inheritance; it is your own property, delivered to you through the liquidation. What a lawyer will want to see is the marriage certificate, any marriage settlement, and the titles or records showing when and how each asset was acquired, since those documents determine what enters the liquidation at all.