Title
De los Santos vs. Reyes
Case
G.R. No. L-10509
Decision Date
Nov 3, 1917
Dispute over probate of Ramon Ocampo's will; claim of P4,017.14 against estate upheld; Gervasia de los Santos' motion denied due to untimely appeal and lack of prejudice.
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Case Digest (G.R. No. L-10509)

Facts:

Background of the Case

  • The case involves the probate of the will of Ramon Ocampo, who was the husband of Raymunda Yaptinchay. Gervasia de los Santos, the mother of Alfredo Ocampo (who claims to be the natural son and sole heir of Ramon Ocampo), filed a motion in the Court of First Instance of Laguna. The court denied her motion, leading to the present appeal.

Probate of Ramon Ocampo's Will

  • On August 10, 1910, the Court of First Instance of the Sixth Judicial District decreed the probate of Ramon Ocampo's will and appointed Francisco Yaptinchay as the testamentary executor of Ocampo's estate. Commissioners of appraisal and claims were also appointed.

Claims Against the Estate

  • Vicente Reyes, the judicial administrator of Raymunda Yaptinchay's estate, filed a claim for P4,017.14 against Ramon Ocampo's estate. He alleged that Ocampo, as the administrator of Raymunda's estate, had in his possession cash and income belonging to Raymunda, which he invested in his own property.

Commissioners' Report

  • The commissioners of appraisal recommended that the claim of P4,017.14 be paid, with deductions for certain amounts, including P200 for Spanish gold coins and legal fees owed to Ramon Ocampo for his services as administrator of Raymunda's estate.

Gervasia de los Santos' Motion

  • Gervasia de los Santos, as the mother and guardian of Alfredo Ocampo, filed a motion to annul the commissioners' report and requested the appointment of new commissioners. She alleged irregularities in the proceedings, including improper admission of evidence and failure to defend the interests of the estate.

Court's Ruling on the Motion

  • The court denied Gervasia de los Santos' motion, ruling that the proceedings were in accordance with the law and that the alleged irregularities did not prejudice the rights of Alfredo Ocampo.

Issue:

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Ruling:

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Ratio:

  1. Compliance with Legal Procedures: The court found that the commissioners and the trial court substantially complied with the provisions of the Code of Civil Procedure, including the publication of notices and the proper handling of claims.
  2. Timeliness of Appeals: Gervasia de los Santos failed to appeal the commissioners' report within the prescribed period, and her subsequent motion to annul the report was untimely. The court emphasized that objections to claims must be raised in a timely manner.
  3. Validity of the Claim: The claim of P4,017.14 was supported by documentary evidence and was not contradicted or challenged as false. The court found no basis to invalidate the claim.
  4. No Prejudice to Rights: The alleged irregularities in the proceedings did not prejudice the rights of Alfredo Ocampo, as Gervasia de los Santos had the opportunity to raise objections during the proceedings but failed to do so.

Conclusion:

  • The Supreme Court upheld the lower court's decision, affirming the validity of the claim against Ramon Ocampo's estate and the legality of the proceedings. Gervasia de los Santos' motion to annul the commissioners' report was denied, and the estate was ordered to pay the claim.


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