Cartajena v. Lijauco
REITERATIONFacts
The Antecedents: Tomasa Nepomuceno died on April 9, 1913. On April 11, 1913, the defendants petitioned for the appointment of an administrator for her estate, alleging intestacy. On April 14, 1913, the plaintiff presented a purported last will and testament of the deceased and prayed for its probate. On July 12, 1913, the court appointed the defendants as administrators. On July 30, 1913, the defendants opposed the probate of the will. On October 30, 1913, the court admitted the will to probate despite the opposition. The defendants appealed this decision, which was affirmed by the Supreme Court on December 15, 1914. On January 30, 1915, the plaintiff was appointed administrator of the estate under the will. Procedural History: While the defendants were acting as administrators and even after the will was admitted to probate and the plaintiff was appointed administrator, the defendants continued to administer the estate. They presented a report of their administration on February 7, 1914, and a motion for partition on February 19, 1914, which was granted on February 27, 1914. On March 9, 1915, the plaintiff filed a motion to annul and set aside all proceedings taken by the defendants after the presentation of the will, pursuant to Section 657 of Act No. 190. The Petition: The plaintiff sought to annul the proceedings conducted by the defendants as administrators after the will was presented for probate, arguing that their authority ceased upon the discovery and allowance of the will.
Issue(s)
Whether an administrator of an estate may continue to administer said estate after a will of the deceased has been proved and allowed.
Ruling
The Court ordered the revocation of the letters of administration granted to the defendants, directed them to render an account of their administration, and to turn over all property and effects to the plaintiff as the duly appointed administrator. All persons holding claims against the estate presented to the commissioners during the defendants' administration were deemed to have been submitted, and claimants who presented their claims in due time were not to be prejudiced.
Ratio Decidendi
On Issue 1: No, an administrator cannot continue to act once a will is proved and allowed. Applying Section 657 of Act No. 190, the Supreme Court held that the appointment of an administrator must be revoked if a will is subsequently discovered and admitted to probate. The Court observed that the defendants could not claim ignorance of the will's existence because they had actively appeared in the probate proceedings to oppose it. The law explicitly mandates that upon the allowance of a will, letters of administration shall be revoked, the powers of the administrator shall cease, and the administrator must surrender their letters and render an account. The Court found it difficult to understand how the defendants could have continued in good faith with the administration after having full knowledge that the will had been proved and allowed. Therefore, the letters previously granted to the defendants must be revoked and they must immediately turn over all property and effects to the plaintiff. To ensure the protection of creditors, the Court further decreed that all claims submitted to the commissioners during the defendants' administration would be considered validly submitted to the new administration to prevent prejudice to claimants.
Main Doctrine
The appointment of an administrator for an intestate estate shall be revoked and their powers shall cease upon the discovery and probate of a will of the deceased, requiring the surrender of letters of administration and rendering of an account.