Case Digest (G.R. No. L-18403)
Facts:
- Mauricia G. de Villanueva filed for letters of administration for her deceased husband Pascual Villanueva's estate on December 19, 1949, in the Court of First Instance of Agusan.
- The hearing notice was published in the Manila Daily Bulletin on February 25, March 4, and March 11, 1950.
- Due to opposition from other heirs, Atty. Teodulo R. Ricaforte was appointed as the administrator instead of Mauricia.
- A notice to creditors was published on November 16, 23, and 30, 1950, with a claim deadline set for November 16, 1951.
- The Philippine National Bank (PNB) submitted a claim of P1,347.45 on July 20, 1953.
- The administrator opposed PNB's claim, citing late filing and the statute of limitations.
- PNB later requested an extension to file its claim, claiming ignorance of the proceedings, but the lower court denied this request.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that PNB's claim was barred by the statute of limitations.
- The court upheld the lower court's decision, confirming that the claim was filed after the November 16, 1951 deadline....(Unlock)
Ratio:
- Courts may extend the filing period for claims against an estate only under special circumstances.
- PNB's claim was filed approximately one year and eight months late, despite the bank's prior knowledge of the administration proceedings.
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Case Digest (G.R. No. L-18403)
Facts:
In the case of De Villanueva v. Philippine National Bank, G.R. No. L-18403, decided on September 30, 1963, the petitioner, Mauricia G. de Villanueva, sought to administer the estate of her deceased husband, Pascual Villanueva. On December 19, 1949, she filed a petition for letters of administration at the Court of First Instance of Agusan, with the hearing scheduled and notice published in the Manila Daily Bulletin on February 25, March 4, and March 11, 1950. During the hearing, opposition arose from other heirs against Mauricia's appointment as administrator, leading to the appointment of Atty. Teodulo R. Ricaforte instead. A notice to creditors was published on November 16, 23, and 30, 1950, informing all potential claimants against the estate to file their claims within six to twelve months from the first publication, setting a deadline of November 16, 1951. On July 20, 1953, the Philippine National Bank (PNB) submitted a creditor's claim against the estate, asserting a total amount due of P1,347.45. In October 1954, PNB moved for the admission of its claim, but the administrator opposed it, citing the claim's validity and arguing that it was barred by the statute of limitations due to its late filing. Subsequently, PNB filed a petition for an extension to submit its claim, claiming ignorance of the administration proceedings. However, the lower court denied this petition, ruling t...