Case Digest (G.R. No. L-29746)
Facts:
This is Intestate Estate of the Late Emilio Camon, Concepcion Ereneta, Administratrix-Appellee v. Ignatius Henry Bezore, Elwood Knickerbocker, and Mary Irene Fallon McCormick, Claimants‑Appellants; Martiniano O. de la Cruz, Administrator, G.R. No. L-29746, November 26, 1973, Supreme Court First Division, Ruiz Castro, J., writing for the Court.The dispute arises from the estate of the late Emilio Camon, who had been the lessee of Hacienda Rosario in Pontevedra, Negros Occidental, for the crop years 1940–41 through 1960–61. One‑half of the hacienda pro indiviso belonged to the appellants Ignatius Henry Bezore, Elwood Knickerbocker and Mary Irene Fallon McCormick (as heirs of Thomas Fallon), while the other half belonged to Petronila Alunan vda. de Sta. Romana, Amparo Sta. Romana and Alberta vda. de Hopon (heirs of Rosario Sta. Romana). Upon Camon’s death in 1967 his widow Concepcion Ereneta petitioned the Court of First Instance of Negros Occidental for letters of administration; the petition was granted and the administratrix was appointed.
Following appointment, the court required creditors to file claims. Through their judicial administrator and counsel Martiniano O. de la Cruz, the appellants filed a monetary claim against the estate for P62,065 (value of sugar allotments and allowances) and P2,100 (palay and rentals), totaling P64,165, representing the appellants’ one‑half share in the hacienda. The administratrix admitted that Camon appropriated the amounts; the appellants had previously demanded payment from Camon during his lifetime without success.
At trial the administratrix introduced three uncontroverted documents: (1) an “Agreement to Sell” dated January 11, 1961 (Exhibit 1) whereby the appellants agreed to sell their one‑half share to Amparo and Alberta; (2) a “Release and Waiver of Claims” dated January 12, 1961 (Exhibit 3) in which Amparo and Alberta purportedly released and waived “any and all claims … pertaining to the two‑fourth pro‑indiviso share … including rights accrued or accruing” in favor of Emilio Camon; and (3) a “Deed of Sale” dated August 4, 1961 (Exhibit 2) in which the appellants sold “all their rights, title, interest and participation, whether accrued or accruing … including its sugar quota” in favor of Amparo and Alberta for P78,000.
The Court of First Instance, by order dated July 20, 1968, held that the Deed of Sale’s clear language (“accrued or accruing”) included the accrued sugar allotments and allowances and thus denied the appellants’ claim against the estate. The appellants appealed directly to the Supreme Court.
Two principal issues were...(Pro-only)
Issues:
- Did the phrase “accrued or accruing” in the Deed of Sale exclude the appellants’ sugar allotments and allowances, thereby allowing their claim against the estate?
- Did Emilio Camon’s continued cultivation of the hacienda after the written lease expired create an express trust in favor of the appellants despite the absence...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)