Contuan v. Ramirez
REITERATIONFacts
The Antecedents: Plaintiffs Aurelia Contuan, Cornelia Espinosa, and Justa Camacho, representing themselves as heiresses and administratrix of deceased partners Wenceslawa de la Cruz, Doroteo de la Cruz, and Sebastian Remigio, respectively, filed a complaint against defendants Fortunata Ramirez and her children. The plaintiffs sought to compel the defendants to deliver the shares corresponding to their respective fathers in the profits of a partnership formed for the exploitation of three fisheries. The deceased Paulino de la Cruz, predecessor in interest of the defendants, was the last manager of the business before his death. Procedural History: The Court of First Instance of Bulacan dismissed the complaint without prejudice to the plaintiffs' right to enforce their claim in proper proceedings against the estate of the deceased Paulino de la Cruz. The counterclaim of the defendants was also dismissed for failure to substantiate their claim and for not requesting the intervention of the administrator of the deceased father's estate. The Petition: Both plaintiffs and defendants appealed the decision of the Court of First Instance.
Issue(s)
Whether the plaintiffs were justified in bringing the suit against the defendants. Whether the Court of First Instance had jurisdiction to try the case.
Ruling
The Supreme Court dismissed the appeal, affirming the dismissal of the complaint and counterclaim by the Court of First Instance. The Court held that it had no jurisdiction to try the case originally, nor jurisdiction to review it on appeal.
Ratio Decidendi
On the issue of whether the plaintiffs were justified in bringing the suit against the defendants: The Court held that the plaintiffs were not justified in bringing the suit directly against the heirs or the judicial administrator. According to the records, intestate proceedings for the estate of the deceased Paulino de la Cruz were pending, and a judicial administrator had been appointed. The claim of the plaintiffs against the estate was for a sum of money alleged to be due from the deceased. Section 702 of the Code of Civil Procedure prohibits actions against heirs when there is a judicial administrator. Furthermore, Section 699 of the same Code prohibits actions against the judicial administrator for such claims. Instead, such claims must be presented to the committee on claims and appraisal appointed in the intestate proceedings, as provided in Section 700 of the Code of Civil Procedure. On the issue of whether the Court of First Instance had jurisdiction to try the case: The Court ruled that the trial court had no jurisdiction to try the case originally, nor did the Supreme Court have jurisdiction to review it on appeal. This is because the law does not permit the bringing of an action for the recovery of a debt due from a deceased person while his estate is under judicial administration. The proper procedure is to file the claim with the committee on claims and appraisal.
Main Doctrine
When an intestate estate is under judicial administration, no action for the recovery of a debt due from the deceased can be brought either against his heirs or against the judicial administrator, but the claim must be presented to the committee on claims and appraisal appointed in the intestate proceedings.