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 amounts 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, specifically concerning the court’s jurisdiction over Pablo Venida.
2. Whether the appellees’ 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 and Jurisdiction of the 1915 Judgment: The Court held that the 1915 judgment was valid and rendered with jurisdiction. The appellees presented a certified copy of the record from Case No. 1747, which showed that Pablo Venida was duly summoned on August 11, 1914. After he failed to appear within the prescribed period, the court properly declared him in default on January 16, 1915, and proceeded to render judgment based on the plaintiff’s evidence. The appellant’s claim, supported only by witness testimony that Pablo Venida was not notified, was insufficient to overcome the official record which established that due process was observed.

2. On Prescription of Action: The Court ruled that the action had not prescribed. The judgment was rendered on February 19, 1915. The complaint to enforce it was filed on March 24, 1924. Applying Section 43, paragraph No. 1 of the Code of Civil Procedure, which provided a ten-year prescriptive period for the enforcement of a judgment, the action was filed well within the prescriptive period.

The Supreme Court found no error in the trial court’s assessment of the evidence and affirmed the judgment ordering the appellant, as administrator, to pay the appellees the amounts stated in the 1915 judgment with the stipulated interest.