G.R. No. 31860, October 16, 1930
IN THE MATTER OF THE ESTATE OF CHARLES C. REAR, DECEASED. J.J. WILSON, administrator-appellee, vs. M. T. REAR, ET AL., heirs-appellants.

FACTS

Charles C. Rear was murdered on July 14, 1925. J.J. Wilson was appointed special administrator of his estate on November 17, 1925. The estate’s property was initially appraised at P20,800, with personal property valued at P5,800 (including livestock appraised at P4,000). The only known debts of the deceased were about P1,300. Due to a lack of funds to pay claims, the court eventually authorized the sale of the estate’s assets. With the heirs’ consent, the property was sold to William Mannion for P7,600. Wilson filed his final account, which the heirs objected to, citing excessive disbursements, unauthorized loans, neglect, waste, and procedural errors by the court. The lower court approved Wilson’s final account, prompting the heirs’ appeal.

ISSUE

Did the lower court err in approving the final amended account of Administrator J.J. Wilson?

RULING

Yes, the lower court erred. The Supreme Court reversed the lower court’s approval of the final account. The Court found that Wilson, as administrator, failed in his legal duty to promptly sell the estate’s personal property to pay debts and administration expenses. The estate began with sufficient personal assets (P5,800) to cover all debts and proper expenses (totaling P3,422.58). Wilson’s administration resulted in a deficit, and he failed to properly account for the livestock. While the Court allowed certain expenses (operating costs for eight months, court costs, administrator’s fees, and the deceased’s debts totaling P5,680.03), it held Wilson liable for the balance. After crediting all cash he received (P9,519.25) against the allowed expenses, Wilson was ordered to pay the heirs P3,839.22, with 6% interest from November 7, 1927. The decision is without prejudice to any action the heirs may take against Wilson’s bondsmen.