G.R. No. 25084, September 4, 1926
RUFINA, WIDOW OF PIMENTEL, ET AL., plaintiffs-appellees, vs. EULALIO VENIDA, as administrator of the intestate estate of Pablo Venida, deceased, defendant-appellant.

FACTS

On February 19, 1915, the Court of First Instance of Camarines Norte rendered a final and executory judgment in Civil Case No. 1747, ordering Pablo Venida to pay Ramon Pimentel specified sums. After the judgment became final, Pablo Venida died. The widow and children of Ramon Pimentel (the appellees) filed a claim for these sums with the committee on appraisal and claims in the intestate proceedings of Pablo Venida’s estate. The committee admitted the claim. The administrator of the estate (the appellant) appealed the committee’s admission, arguing procedural defects and lack of jurisdiction in the original case. The lower court ruled in favor of the appellees, ordering the administrator to pay the judgment debt with interest. The administrator appealed, contesting the validity of the 1915 judgment.

ISSUE

1. Whether the 1915 judgment in Civil Case No. 1747 is valid and enforceable against the estate of Pablo Venida, considering the appellant’s claim that it was rendered without jurisdiction over the person of Pablo Venida due to lack of summons.
2. Whether the action to enforce the judgment had prescribed.

RULING

The Supreme Court AFFIRMED the lower court’s decision, upholding the validity and enforceability of the 1915 judgment.

1. On the Validity of the 1915 Judgment: The Court held that the appellant’s contention of lack of jurisdiction was untenable. The certified copy of the record in Case No. 1747 showed that a motion was filed alleging the defendant was duly summoned, and based on this, the court declared Pablo Venida in default for failure to appear. The judgment, having become final and executory, enjoys the presumption of regularity. The appellant’s testimonial evidence to the contrary was insufficient to overcome the official record.

2. On Prescription of Action: The Court ruled that the action had not prescribed. The judgment was rendered on February 19, 1915, and the complaint to enforce it was filed on March 24, 1924. This period is within the ten-year prescriptive period for enforcing judgments under Section 43, paragraph No. 1, of the Code of Civil Procedure (now Section 6, Rule 39 of the Rules of Court).

The Court also found no error in the trial court’s assessment of the witnesses’ credibility. Accordingly, the appealed judgment was affirmed.