Title
Valuis vs. Vda. e Hijos de Cu Toco
Case
G.R. No. 47193
Decision Date
Jan 27, 1941
Hugo Ocampo died intestate in 1933; creditors filed claims against his estate. A committee approved most claims; Vda. e Hijos de Cu Toco appealed partial disallowance. Their awarded amount was deemed executory as administratrix didn’t appeal. Supreme Court affirmed payment.
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Case Digest (G.R. No. 47193)

Facts:

    Initiation of the Estate Proceedings

    • On September 10, 1936, Sy Cong Bieng & Co., Inc., through counsel, filed a petition in the Court of First Instance of Camarines Sur for the issuance of letters of administration for the estate of the deceased Hugo Ocampo Cu Jongco.
    • The petition alleged several points:
    • Hugo Ocampo Cu Jongco died intestate in 1933 in Tinanbac, Camarines Sur.
    • He left a real property valued at P14,880.
    • He was survived by his wife, Remigia Valuis, and three or four children.
    • He was indebted to the petitioner in the amount of P3,560.24.

    Appointment of Administratrix and Committee Formation

    • On December 5, 1936, the court appointed Remigia Valuis, the widow of the deceased, as the administratrix of the estate.
    • The court also named Jose Sy Ping, Sy Tangco, and Joaquin Cardena as members of the committee on claims and appraisal.
    • On February 20, 1937, upon motion of the administratrix, the court appointed Martin Don as a new member of the committee, succeeding Jose Sy Ping.

    Call for and Submission of Claims

    • The committee on claims and appraisal announced, through the weekly newspaper "Tignog Nin Bunuaan," that it was ready to receive claims against the estate.
    • On June 19, 1937, Vda. e Hijos de Cu Toco filed its claim amounting to P1,718.89, representing the balance of a current account the deceased maintained with it.
    • Other creditors who filed claims included:
    • The newspaper "Tignog Nin Bunuaan."
    • Mariano Dy-Liaco & Sons.
    • The Collector of Internal Revenue, through the provincial fiscal.

    Committee’s Resolution and Subsequent Appeals

    • On July 28, 1937, the committee rendered its report:
    • It approved all the submitted claims.
    • It allowed the claim of Vda. e Hijos de Cu Toco only up to P1,416.06 after deducting P302.83 for lumber previously delivered by the deceased.
    • Upon notification of the committee’s report:
    • Vda. e Hijos de Cu Toco appealed the partial disallowance of its claim before the Court of First Instance of Camarines Sur.
    • They also moved for the execution of the awarded sum, P1,416.83, pending the resolution of their appeal.
    • The administratrix opposed the motion for execution.
    • On December 15, 1937, the lower court, concluding that the committee’s resolution had become final and executory due to the absence of an appeal from the administratrix, ordered the payment of the awarded sum to Vda. e Hijos de Cu Toco.
    • The administratrix’s motion for reconsideration was denied.

    Issues Raised on Appeal

    • The appeal from the administratrix (Remigia Valuis, the appellant) contested:
    • The holding that the committee’s resolution had become final and executory.
    • The order directing immediate payment of the awarded sum pending the appeal of Vda. e Hijos de Cu Toco.
    • The allowance of such payment, which purportedly prejudiced the interests of other creditors of the decedent's estate.

Issue:

  • Whether the failure of the administratrix to timely appeal the committee’s resolution results in the de facto finality and executory effect of the report, notwithstanding the subsequent appeal by a creditor.
  • Whether the appeal by Vda. e Hijos de Cu Toco, contesting the partial disallowance of its claim, effectively stays the execution of the committee’s award.
  • Whether the lower court erred in ordering the immediate execution and payment of P1,416.83 against the administratrix, considering the appeal pending from the creditor and the potential prejudice to other creditors’ interests.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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