Case Summary (G.R. No. L-14713)
Background of the Case
On July 12, 1957, Apolinario S. de Guzman filed a claim for ₱1,000 against the estate of Arsenio E. Afan, which he alleged was due from Afan as indicated in a promissory note dated August 16, 1949. This claim was presented during a special proceeding for the settlement of the intestate estate. However, the administratrix of the estate objected to this claim, asserting that it was filed beyond the prescribed period for the presentation of claims.
Lower Court’s Ruling
The Court of First Instance of Manila issued an order on July 27, 1957, which refused to entertain De Guzman’s claim. The lower court based its decision on the assertion that the claim was not filed within the mandated period established by Rule 87 of the Rules of Court. Specifically, the lower court noted that De Guzman did not meet the necessary conditions for filing a late claim.
Legal Provisions and Argument
De Guzman relied on Section 2, Rule 87 of the Rules of Court, which allows the court to permit the late filing of claims prior to the distribution of an estate, provided certain conditions are met, such as filing an application, showing cause, and adhering to a one-month limit for extending the claim-filing period. De Guzman failed to submit an application or present any justification for his delay.
Court Analysis
The court emphasized that the discretion to grant late filings is contingent on the claimant providing a valid cause for the delay, which De Guzman did not sufficiently articulate. The court also highlighted that De Guzman had been aware of the intestate proceedings since August 1955, as he had previously engaged in litigation against Afan prior to his death and was subsequently informed about the probate status.
Delay and Lack of Cause
De Guzman's failure to file the claim until July 27, 1957, despite being aware of the ongoing estate proceedings, underm
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Case Overview
- The case pertains to an appeal by Apolinario S. de Guzman regarding an order from the Court of First Instance of Manila dated July 27, 1957.
- The appeal arises from a claim filed by De Guzman for P1,000, plus interest, based on a promissory note issued by the deceased, Arsenio E. Afan.
- The administratrix of Afan's estate contested the claim, arguing it was filed post the deadline for claims against the estate.
Background Facts
- De Guzman filed his claim on July 12, 1957.
- The claim was opposed by the estate's administratrix on the grounds of late filing.
- The lower court denied the claim based on the timing of its submission relative to the established deadline for claims.
Legal Provisions Cited
- De Guzman cited Section 2, Rule 87 of the Rules of Court which outlines the timeframe within which claims must be filed.
- The rule stipulates that claims can be filed within a period not exceeding one month after the original deadline, contingent upon the creditor showing cause and obtaining permission from the court.
Arguments from the Parties
De Guzman's Argument:
- He argued that since his claim was filed before the