Facts:

This case, entitled Jesusa Lacson de Arroyo, Administratrix and Appellee, vs. Visayan General Supply Company, Inc., Claimant and Appellant, emerged from the Court of First Instance of Iloilo regarding the intestacy of Jose Maria Arroyo y Pidal, who passed away in Italy on March 8, 1927. Shortly after his death, on March 12, 1927, a petition for the appointment of an administrator was filed, which led to Ignacio Arroyo being appointed as a special administrator, followed by Jesusa Lacson de Arroyo, the decedent's widow, as the permanent administratrix on May 23, 1927. During the decedent's lifetime, he maintained an open account with Visayan General Supply Company, Inc., which claimed an outstanding balance of P220,974.06 for unpaid debts. This claim was presented to a committee appointed for examining claims against the estate by Lucio Echaus, who was the corporation's vice-president and acting general manager. However, the Visayan General Supply Company was dissolve

...

Facts:

Decedent and Estate Administration

• Jose Maria Arroyo y Pidal, a resident of the Province of Iloilo, died in Italy on March 8, 1927.
• A petition was filed three days after his death in the Court of First Instance of Iloilo seeking the appointment of an administrator for his estate.
• Ignacio Arroyo was appointed as special administrator on March 12, 1927.
• Jesusa Lacson de Arroyo, the widow of the decedent, was appointed permanent administratrix on May 23, 1927.
• Concurrently, a committee on claims was established for the purpose of receiving and examining claims against the estate.

The Visayan General Supply Company, Inc. and the Claim

• The Visayan General Supply Company, Inc. was incorporated in 1922 in the Philippine Islands, with its office in Iloilo and an authorized capital of P1,000,000.
• Its paid-up capital was nominal (P50,100 of the P200,000 subscribed) because much of the funds were obtained through the transfer of bad debts from its principal stockholder, Enrique Echaus.
• Before the claim was filed, the corporation had been involved in irregular operations; it had borrowed and lent large sums of money, leading to its financial difficulties.
• The government, represented by the Attorney-General, initiated dissolution proceedings due to these irregularities, and a judgment dissolving the corporation was rendered on March 18, 1927, by Judge Santamaria in the Court of First Instance of Iloilo.

Presentation and Rejection of the Claim

• At the time of his death, the decedent had an open account with the Visayan General Supply Company, Inc.
• On November 10, 1927, Lucio Echaus—formerly vice-president and acting general manager of the corporation—presented a claim amounting to P220,974.06 against the decedent’s estate before the committee on claims.
• Jesusa Lacson de Arroyo, as administratrix, opposed the claim on the ground that the corporation had been dissolved, arguing that no legal authority remained for the corporation to present or maintain such a claim.
• The committee on claims, relying on the administrative opposition and the fact of dissolution, rejected the claim without considering it on its merits.
• The report of the committee was approved by the court on December 24, 1927.

Subsequent Motion and Appeal

• Although the claim was rejected, no appeal was immediately taken against the committee’s action.
• On May 24, 1928, Rodrigo Villanueva, acting as receiver of the defunct corporation, filed a motion under Section 690 of the Code of Civil Procedure to renew the commission of the committee on claims so that the claim might still be filed and considered.
• The trial court denied the motion on June 28, 1928.
• The Visayan General Supply Company, Inc., through its receiver, then prosecuted the present appeal.

Issue:

Whether Lucio Echaus, acting as the former vice-president and acting general manager, had any legal authority to present a claim on behalf of the dissolved Visayan General Supply Company, Inc.

• Examination of the effect of the corporation’s dissolution on its legal personality and the authority of its officers.
• The legal implications of an unauthorized submission of a claim.

Whether the action of the committee on claims in rejecting the claim solely on the ground of dissolution, without considering its merits, was proper.

• The validity and effect of the committee’s rejection based on procedural concerns.
• The possibility of a subsequent filing or renewal of the committee’s commission under Section 690.

Whether the application under Section 690 of the Code of Civil Procedure, filed within the prescribed six-month period, should have been granted despite the error in representation by Lucio Echaus.

• The interpretation of Section 690 regarding the renewal of the commission.
• Analogies to other cases (for example, Estate of Tiangco) regarding timely presentation and negligence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)