GR L 45400; (April, 1939) (Digest)
G.R. No. L-45400; April 14, 1939
In the matter of the guardianship of Remigio Paquiao. MARCIANA LUNASCO, petitioner-appellant, vs. VETERANS ADMINISTRATION, oppositor-appellee.
FACTS
Remigio Paquiao, a minor, was the beneficiary of a monthly pension from the U.S. Veterans Administration following the death of his father, a veteran. His grandmother, Marciana Lunasco, cared for and supported him for eleven and a half months before a legal guardian, the Philippine Trust Company, was appointed. After the guardian’s appointment, Lunasco filed a petition in the Court of First Instance of Rizal seeking reimbursement of P230 for the support and education she provided during that period before the guardian received the pension funds. The Veterans Administration opposed, citing Section 3 of U.S. Public Act No. 362, which exempts veterans’ benefit payments from the claims of creditors. The lower court sustained the opposition and denied Lunasco’s claim.
ISSUE
Whether Marciana Lunasco is entitled to reimbursement from the pension funds received by the guardian for expenses she incurred in supporting the minor before the guardian’s appointment.
RULING
No. The Supreme Court modified the lower court’s order. Interpreting Section 3 of U.S. Public Act No. 362, and following precedents from New York and California courts, the Court held that veterans’ benefit payments are exempt from claims for debts incurred before receipt by the beneficiary or guardian. Therefore, Lunasco’s claim for expenses incurred before the appointment and qualification of the guardian on April 18, 1936, is not allowable. However, claims for the support and maintenance of the minor incurred after the guardian’s appointment may be paid from the funds, as they are considered obligations incurred by the guardian. Thus, only the portion of Lunasco’s claim pertaining to expenses after April 18, 1936, was approved.
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