Case Digest (G.R. No. L-13489)
Facts:
The case involves the Bank of the Philippine Islands (BPI), which serves as the executor of the testate estate of the late Graciana de Jesus. The proceedings took place in the Court of First Instance of Manila under Special Proceeding No. 18033. The dispute arose when the BPI submitted a statement of accounts that included two items of expense: P1,461.00 for the cost of stenographic notes from a hearing related to Civil Case No. 22828, which the BPI filed against Jose J. Gonzales to annul a deed of donation executed by Graciana de Jesus in favor of Gonzales, and P56.00 for the cost of printing a brief for an appeal regarding a consulta from the Land Registration Commission concerning a notice of lis pendens on the same property. The trial court disallowed these expenses, ruling that they were not chargeable against the estate. The will of Graciana de Jesus, dated February 1, 1945, named Angustia Jimenez as the legatee of three parcels of land in Manila, which were later the s...
Case Digest (G.R. No. L-13489)
Facts:
Executor's Role and Disallowed Expenses
- The Bank of the Philippine Islands (BPI), acting as the executor of the testate estate of Graciana de Jesus, submitted a statement of accounts to the Court of First Instance of Manila (Special Proceeding No. 18033).
- Two items in the statement were disallowed by the court:
- P1,461.00: Cost of stenographic notes from the hearing of Civil Case No. 22828, where BPI sought to annul a deed of donation inter vivos executed by the deceased in favor of Jose J. Gonzales.
- P56.00: Cost of printing the brief filed by BPI in its appeal to the Supreme Court (G.R. No. L-12128) regarding a consulta on the annotation of a notice of lis pendens on the property in question.
Background of the Case
- Graciana de Jesus left a will dated February 1, 1945, naming Angustia Jimenez as the legatee of three parcels of land in Manila.
- The same parcels were later donated by the deceased to Jose J. Gonzales through a deed of donation inter vivos.
- BPI, as executor, filed Civil Case No. 22828 to annul the donation and recover the properties for the estate.
- A notice of lis pendens was annotated on the title of the properties.
Mortgage and Foreclosure
- Gonzales mortgaged the properties to Ramon Eugenio, who later foreclosed the mortgage due to non-payment.
- The properties were sold at a foreclosure sale to Consuelo O. Vda. de Eugenio, who requested the issuance of a new title free from liens.
- BPI objected, leading to a consulta with the Land Registration Commission, which ruled against the annotation of the notice of lis pendens. BPI appealed this ruling to the Supreme Court.
Appellant's Argument
- BPI argued that the disallowed expenses were incurred in its capacity as executor and were necessary to fulfill its duties under the probated will.
Oppositor's Argument
- Jose J. Gonzales contended that the expenses were improper because the action to annul the donation primarily benefited Angustia Jimenez, the legatee, and not the estate.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Executor's Duty to Collect Assets
- As executor, BPI was tasked with carrying out the provisions of the probated will, which included devising the properties to Angustia Jimenez.
- It was BPI's duty to take all necessary legal steps to recover the properties and ensure they were distributed according to the will.
Expenses as Administration Costs
- The expenses incurred (stenographic notes and printing of the brief) were directly related to BPI's duty to gather and protect the estate's assets.
- Under Section 7, Rule 86 of the Rules of Court, an executor is entitled to reimbursement for necessary expenses in the care, management, and settlement of the estate.
Benefit to the Estate
- The actions taken by BPI were not merely to accommodate Angustia Jimenez but were necessary to fulfill its fiduciary duty to the estate.
- The expenses were incurred in the interest of the estate and were therefore chargeable against it.