G.R. No. 93986 - Loong vs. Commission on Elections

The case involves the testate estate of the late Felix J. de Guzman of Gapan, Nueva Ecija.
The deceased was survived by eight children – Victorino, Librada, Severino, Margarita, Josefina, Honorata, Arsenio, and Crispina – as provided in his last will and testament.
The will was duly probated, and letters of administration were issued to his son, Doctor Victorino G. de Guzman, by the Court of First Instance of Nueva Ecija (Order dated September 17, 1964).

Among the assets, a residential house located in the poblacion was included.
In conformity with the testator’s will, the house and lot were partitioned among the heirs, with each receiving a one-eighth pro-indiviso share.
A project of partition was executed on March 19, 1966, signed by the heirs and approved by the lower court on April 14, 1967, though the final settlement of the estate was still pending.

The administrator, Victorino G. de Guzman, submitted four accounting reports covering the period from June 16, 1964, to September 1967.
The accounts disclosed various disbursements amounting to P13,610.48, which were categorized into four main expense groups.

Expenses for the improvement and renovation of the decedent’s residential house (Totaling P10,399.59):

Living expenses of Librada de Guzman during her occupancy of the family home without paying rent (Totaling P1,603.11):

The probate court, in its August 29, 1966 order, had directed the administrator not to spend estate assets for reconstructing or remodeling the decedent’s house, unless authority was secured from the court.
Despite this instruction, the lower court, in its order dated April 29, 1968, later allowed the disputed expenses as legitimate administration expenses.
Three heirs – Crispina de Guzman-Carillo, Honorata de Guzman-Mendiola, and Arsenio de Guzman – objected to certain disbursements, contending that some expenses were either not necessary or not allowable under the Rules of Court.

Whether the expenses incurred for the construction of a fence, renovation of the bathroom, and repair of the terrace/interior of the family home qualify as necessary administration expenses under the Rules of Court.
Whether such disbursements fall within the duty of the administrator to maintain and preserve the estate’s real property for eventual partition and distribution among co-owners.

Whether the disbursements for the living expenses of Librada de Guzman (house helper’s salary, utility bills, and related items) are personal expenses or legitimate administration expenses.
Whether the occupancy of the family residence by one heir without rent should entitle the estate to bear personal living costs.

Whether certain items under “Other Expenses” (e.g., stenographic notes, representation expenses, and expenditures related to the first death anniversary) are properly connected to the care, management, and settlement of the estate.
Whether these expenses meet the criteria for reasonable and necessary disbursements of an administrator.

Whether the irrigation fee paid to the Penaranda Irrigation System is appropriately accounted for as a farming expense tied to the management of the estate.
Whether any potential duplication with other irrigation-related disbursements (such as the previously noted P1,320 allotment) affects its legitimacy.