Facts:

The case involves the intestate estate of Josefa Garcia Pascual, with Luis Palomar Baldovi serving as the ex-administrator and the appellee being the estate itself. Baldovi was appointed as the judicial administrator of the estate by the Court of First Instance of Albay on December 9, 1902. He presented his first account of administration on April 20, 1904, claiming it contained all details regarding the estate's financial transactions, except for his due percentage. He subsequently submitted a second yearly account on April 24, 1905, and a final account on March 19, 1906. In his final account, Baldovi noted that certain rentals had not been collected and that some expenses, including his salary and attorney fees, were not included.

During the proceedings, Angel Ortiz, a creditor of the estate, filed objections against Baldovi's accounts, claiming they were inaccurate. On March 5, 1906, Ortiz's attorneys formally objected to the first two accounts, and on March...

Facts:

Appointment and Administration of the Estate:

• Luis Palomar Baldovi was appointed judicial administrator of the intestate estate of Josefa Garcia Pascual by the Court of First Instance of Albay on December 9, 1902.
• He rendered his first account of administration on April 20, 1904, covering the period from his appointment to April 16, 1904.
• On April 24, 1905, he presented the second yearly account, and on March 19, 1906, he rendered his final account, noting uncollected rentals and other omissions.

Creditors and Objections:

• Angel Ortiz, a creditor claiming over P300,000, objected to the first two accounts rendered by Baldovi on March 5, 1906.
• Mendezona & Co., another creditor, concurred with Ortiz's objections on March 8, 1906.
• On March 24, 1906, Ortiz's attorneys also objected to Baldovi's final account, requesting its rejection or modification.

Removal of Baldovi and Appointment of New Administrator:

• In early March 1906, Baldovi was removed as administrator, and Arlington U. Betts was appointed in his place.
• Betts took charge of the administration on March 13, 1906.

Key Issues in the Accounts:

• Baldovi's accounts included uncollected rentals, unpaid salaries, and unauthorized expenses, such as the construction of a house in Daraga using estate funds.
• The court disallowed certain expenses and declared the sale of property in Nueva Caceres null and void due to Baldovi exceeding his authority.

Issue:

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Ruling:

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Ratio:

1. Duty to Render Accounts: Under Section 672 of the Code of Civil Procedure, an administrator is required to render accounts of their administration, and the court has the authority to examine and approve or reject these accounts.
2. Exceeding Authority: An administrator who exceeds their authority, such as by selling property without proper judicial approval, acts unlawfully, and such actions are void.
3. Unauthorized Expenses: Expenses incurred without judicial authority, such as the construction of a house using estate funds, are not justified and must be reimbursed by the administrator.
4. Interest on Unpaid Amounts: An administrator who fails to pay amounts owed to the estate is liable for legal interest on those amounts from the date they ceased to act as administrator.
5. Finality of Orders: Orders of the court that are not appealed or questioned in the bill of errors become final and cannot be revisited.