G.R. No. 13153 ; September 23, 1918
SANTOS CARTAJENA, as executor of the deceased Tomasa Nepomuceno, and TEOTIMO DUQUE and LUCIANO NEPOMUCENO, plaintiffs-appellants, vs. ISAIAS LIJAUCO and ESPERANZA ZABALLA, in their capacity of guardians and tutors of the minors, Ana Cartajena and Manuel Lijauco, defendants-appellees.

FACTS:
Tomasa Nepomuceno died on April 9, 1913. On April 11, 1913, the defendants petitioned for the appointment of an administrator for her estate, and the court appointed them as such on July 12, 1913. However, on April 14, 1913, the plaintiff Santos Cartajena had already presented for probate the alleged last will and testament of the deceased. The defendants opposed the probate of this will. Notwithstanding the opposition, the court admitted the will to probate on October 30, 1913, and this decision was affirmed by the Supreme Court on December 15, 1914. On January 30, 1915, the lower court appointed the plaintiff as the executor under the will. Despite the probate of the will and the appointment of the plaintiff as executor, the defendants continued to act as administrators of the estate, even submitting reports and motions for partition. The plaintiff thus moved to annul all proceedings taken by the defendants after the presentation of the will, pursuant to Section 657 of Act No. 190 (the Code of Civil Procedure).

ISSUE:
May an administrator, appointed for the estate of a deceased person presumed to have died intestate, continue to administer the estate after a will of such deceased person is duly proved and allowed by the court?

RULING:
No. Under Section 657 of Act No. 190 , if after granting letters of administration on the estate of a person as if he died intestate, a will of the deceased is subsequently proved and allowed by the court, the letters of administration must be revoked and the powers of the administrator cease. The administrator is then required to surrender the letters and render an account to the court. The defendants, having full knowledge of the presentation, probate, and allowance of the will, as they actively opposed it, acted in disregard of the law by continuing their administration. Therefore, the Supreme Court ordered: (a) the revocation of the letters of administration granted to the defendants; (b) the rendition of an account of their administration within a time fixed by the lower court; and (c) the immediate turnover of all estate property and effects to the plaintiff as the duly appointed executor. The Court further ruled that claims presented to the commissioners during the defendants’ administration should be considered properly submitted to preserve the rights of claimants. The judgment of the lower court was affirmed with these modifications.