Title
Bank of the Philippine Islands vs. Belzunce
Case
G.R. No. 11179
Decision Date
Mar 14, 1917
Bank of the Philippine Islands sued Ruperto Bulzunce's estate for P50,000. Appellant contested jurisdiction, but Supreme Court upheld lower court's ruling, affirming presumption of jurisdiction.
Font Size:

Case Digest (G.R. No. 11179)

Facts:

    Parties Involved

    • Plaintiff and Appellee: The Bank of the Philippine Islands, which initiated the suit for the recovery of a sum of money.
    • Defendant and Appellant: Agustin Belzunce, acting as the administrator of the estate of the deceased Ruperto Bulzunce.

    Nature of the Claim

    • The plaintiff sought payment in the amount of P50,000.
    • The claim included an interest component calculated at 9 percent per annum, with the interest compounded quarterly from January 22, 1913, until final payment.

    Procedural Background

    • The case originated in the Court of First Instance of the Tenth Judicial District, where a judgment was rendered in favor of the plaintiff.
    • The appeal raised the single issue regarding the jurisdiction of the Court of First Instance, particularly because the claim was against a deceased individual.

    Alleged Jurisdictional Issues

    • The appellant contended that, due to the claim being based on a deceased person’s estate, the plaintiff was obligated to present evidence of the following:
    • That the claim had been duly presented to the commissioners appointed to hear claims against the deceased's estate.
    • That the commissioners had rejected the claim.
    • That an appeal was taken from this rejection to the Court of First Instance in accordance with the law.
    • It was argued that the record failed to show these preliminary steps, thereby challenging the jurisdiction of the trial court.

Issue:

    Jurisdictional Question

    • Whether the Court of First Instance had jurisdiction to render a judgment on a claim against the estate of a deceased person without explicit evidence of the mandated preliminary procedures (i.e., presentation to the commissioners, their rejection, and the subsequent appeal).
    • Whether the necessary legal steps to confer jurisdiction on the court could be presumed to have been taken in the absence of evidence to the contrary.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur is an AI-powered legal research platform in the Philippines for case digests, summaries, and jurisprudence. AI-generated content may contain inaccuracies; please verify independently.