G.R. No. 112796 - Lagazo vs. Court of Appeals

On May 10, 1952, Numeriano Bautista, husband and father of the plaintiffs-appellees, was a passenger in a jeepney operated on Taft Avenue, Pasay City.
The jeepney, bearing Plate No. TPU-4013, was owned by Rosendo de Guzman, the deceased husband and father of the defendants-appellants, and formed part of his transportation business.
Eugenio Medrano y Torres, employed by Rosendo de Guzman as the driver, drove the vehicle in a negligent and reckless manner leading to the jeepney turning turtle and causing fatal injuries to Numeriano Bautista.

The driver, Eugenio Medrano, was charged and subsequently convicted by the trial court for homicide through reckless imprudence, as reflected in a decision promulgated on May 27, 1952.
Medrano was sentenced to four (4) months and one (1) day of arresto mayor and was ordered to indemnify the heirs of Numeriano Bautista in the sum of P3,000.00.
A writ of execution was issued against Medrano for the amount awarded but was returned unsatisfied.

Rosendo de Guzman died on May 12, 1952.
Plaintiffs-appellees subsequently filed a complaint (Cavil Case No. 2050) on October 7, 1952, seeking:

The lower court dismissed the complaint on May 11, 1953, emphasizing that money claims against a deceased must be filed through probate proceedings, either as a probate action or as a counterclaim in actions initiated by the executor or administrator.

On December 14, 1954, plaintiffs-appellees refiled a complaint in Civil Case No. 3530 with analogous allegations but added:

Allegation that Rosendo de Guzman died intestate on June 12, 1952;
Proceedings (Special Proceedings No. 1303-P) had already been filed and closed with a project of partition approved, distributing the estate among the heirs.

The refiled complaint also claimed additional damages of P15,000.00 for moral, exemplary, and compensatory damages, plus P2,000.00 in attorneys’ fees.
Defendants-appellants again filed a motion to dismiss on May 5, 1955, arguing lack of jurisdiction, absence of a cause of action, and raising res judicata based on the dismissal of the earlier complaint.
The trial court denied the second motion to dismiss on August 22, 1955 and later rendered a decision on August 26, 1961 (with a correction noting the date should be August 14, 1961).

Defendants-appellants assigned multiple errors, alleging that the trial court erred by:

Not sustaining the motion to dismiss on jurisdictional grounds;
Failing to recognize that the plaintiffs-appellees’ claim was barred for not presenting it in the intestate proceedings;
Ignoring the defense of res judicata based on the final dismissal of the earlier case;
Erroneously ordering them to pay P3,000.00 with interests and costs; and
Dismissing their counterclaim without a decision.

The appellate review raised the single controlling question of whether the trial court erred in giving due course to the complaint despite the failure to present the money claim within the mandatory probate or intestate proceedings of the deceased Rosendo de Guzman.

Whether the trial court erred in denying the defendants-appellants’ motion to dismiss on the following grounds:

Lack of jurisdiction over a suit against a deceased person’s estate filed outside the prescribed probate framework.
The failure of the complaint to state a cause of action since the claim should have been presented in testate or intestate proceedings.

Whether the complaint of the plaintiffs-appellees was barred due to their negligence in filing their claim within the intestate proceedings of the estate of the deceased Rosendo de Guzman.

The mandatory requirement under Section 5, Rule 86 enforcing timely presentation of money claims against a decedent.
The implications of the intestate proceedings having already terminated and the estate already distributed.

Whether the trial court erred in refraining from sustaining the defense of res judicata based on the final dismissal of the earlier complaint (Civil Case No. 2050).

Whether it was erroneous for the trial court to impose joint and several liability on the defendants-appellants for the P3,000.00 awarded.

Whether the dismissal of the defendants-appellants’ counterclaim, without rendering any decision on it, constituted reversible error.