G.R. No. 42142 - Bachrach Motor Co., Inc. vs. Albert

The case originates from civil case No. 4399 of the Court of First Instance of Occidental Negros involving the Intestate Estate of the deceased Quirino Peralta and Ursula Genii.
Jose Peralta was appointed as the administrator of the estate and duly submitted annual statements of account until October 14, 1932.

On May 5, 1936, the administrator, through counsel and with the unanimous consent of all the heirs, moved to be relieved from the duty of rendering a final account, citing reasons detailed in his petition.
The Court of First Instance of Occidental Negros granted the motion on May 26, 1936, thereby releasing the administrator from his obligation to present a final account.

On August 11, 1936, a project of partition was approved and the properties of the estate were distributed accordingly.
On February 24, 1939, Vicente Peralta, one of the heirs, filed a motion requesting the administrator to render a final account covering the period from October 14, 1932, to the present, a request which was subsequently denied by the lower court.

The duty of the administrator to render periodic accounts is set out in Chapter XXXII, Section 672 of the Code of Civil Procedure, which mandates that every administrator shall render an account within one year from receiving letters of administration, and further accounts as may be required by the court until the estate is completely settled.
This provision is also embodied in Section 8 of Rule 86 of the New Rules of Court.
The legal requirement for periodic reporting reflects the obligation of an administrator to provide transparency not only to the heirs but also to legatees and creditors of the deceased.

The main issue arose as a result of Vicente Peralta’s later motion for a final accounting covering the period excluded by the earlier discharge.
The appeal challenges the lower court’s decision to maintain the release of the administrator from his final accounting duty.

Whether the lower court erred in not requiring the administrator, Jose Peralta, to render a final account covering the period from October 14, 1932, up to the present, as requested by Vicente Peralta.
Whether the waiver and release of the administrator’s obligation to render a final account—by express agreement or by implication through long continued acquiescence—can be subsequently revoked or set aside.
Whether the exercise of the courts’ discretionary powers in releasing an administrator from his duty to render further accounts was correctly applied in the context of the statutory provisions and established case law.