Case Digest (G.R. No. 43082) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pablo Lorenzo, as Trustee of the Estate of Thomas Hanley, Deceased, vs. Juan Posadas, Jr., Collector of Internal Revenue (64 Phil. 353; G.R. No. 43082; June 18, 1937), the plaintiff, Pablo Lorenzo, was appointed trustee of the estate of Thomas Hanley, who died on May 27, 1922, in Zamboanga. Hanley left a will directing his real estate to be held in trust for ten years for the education of his brother’s descendants and thereafter delivered to his nephew, Matthew Hanley, abroad. The Court of First Instance of Zamboanga admitted the will to probate on June 14, 1922, and appointed P. J. M. Moore as trustee on March 10, 1924; Lorenzo succeeded him on February 29, 1932. The Collector of Internal Revenue assessed inheritance tax of ₱1,434.24 on the estate’s value at death (₱27,920 realty and ₱1,465 personalty, less ₱480.81 deductions) plus interest and surcharge totaling ₱2,052.74. On September 15, 1932, Lorenzo paid under protest and sued for refund and interest, while the Collecto Case Digest (G.R. No. 43082) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Background
- On October 4, 1932, Pablo Lorenzo, as trustee of the estate of Thomas Hanley (deceased), sued Juan Posadas, Jr., Collector of Internal Revenue, in the Court of First Instance of Zamboanga for refund of ₱2,052.74 paid as inheritance tax plus 6% interest from September 15, 1932.
- The Collector counterclaimed ₱1,191.27 as additional interest allegedly due on the same tax. The trial court dismissed both the complaint and counterclaim; both parties appealed.
- Estate and Trust Administration
- Thomas Hanley died May 27, 1922, leaving realty (₱27,920) and personalty (₱1,465), and a will directing (a) money to nephew Matthew Hanley; (b) executors to manage realty for 10 years for Matthew’s benefit; (c) after 10 years absolute gift to Matthew.
- Probate began June 14, 1922. On March 8, 1924, P. J. M. Moore was appointed trustee (took oath March 10, 1924), served until February 29, 1932; Lorenzo succeeded him.
- During Lorenzo’s incumbency, the Collector assessed inheritance tax: tax ₱1,434.24 plus monthly 1% interest from July 1, 1931 and 25% surcharge, totaling ₱2,052.74. A motion to compel payment was granted March 15, 1932; Lorenzo paid under protest September 15, 1932.
Issues:
- Plaintiff-Appellant’s Assignments of Error
- Did Hanley’s real property vest in Matthew at death, making him immediate owner?
- Was there delinquency in payment of the inheritance tax?
- Should tax be based on estate value at death or at the end of the 10-year trust?
- Are trustees’ compensation and fees deductible under §1539, Revised Administrative Code?
- Was the trial court wrong in denying a new trial and judgment for plaintiff?
- Defendant-Appellant’s Assignment of Error
- Should the plaintiff-trustee pay ₱1,191.27 as interest from April 10, 1924, to June 30, 1931?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)