G.R. No. 33139, October 11, 1930
THE GOVERNMENT OF THE PHILIPPINE ISLANDS, plaintiff-appellant, vs. JOSE MA. PAMINTUAN, ET AL., defendants-appellees.

FACTS

Florentino Pamintuan died on April 24, 1925. Intestate proceedings were instituted, and a committee on claims and appraisals was duly appointed. The committee published notices, held sessions, and submitted a report on December 1, 1925, which was approved by the court. The report listed only certain claims presented and approved; no claim for unpaid income taxes was filed by the government. The estate was distributed to the heirs (defendants) on July 6, 1926, after payment of inheritance taxes, and the intestate proceedings were closed on October 27, 1926. Subsequently, on February 16, 1927, the government discovered that Florentino Pamintuan had failed to pay an additional income tax and surcharge of P462 for the year 1919, arising from the undisclosed profit from the sale of a property. Demand for payment was made on the heirs, who refused to pay.

ISSUE

Whether the government’s claim for unpaid income taxes against the estate of a deceased person is barred for failure to file it with the committee on claims and appraisals during the intestate proceedings.

RULING

No. The government’s claim for unpaid income taxes is not barred. The Supreme Court held that claims for taxes due to the government, whether assessed before or after the death of the decedent, are not required to be presented to the committee on claims and appraisals in testate or intestate proceedings. This principle is supported by the weight of judicial authority and was reiterated in the case of Pineda vs. Court of First Instance of Tayabas and Collector of Internal Revenue (52 Phil., 803). Consequently, the tax may be collected even after the distribution of the estate. The heirs are liable for the payment of the unpaid income tax in proportion to their respective shares in the inheritance, pursuant to Section 731 of the Code of Civil Procedure and the doctrine in Lopez vs. Enriquez (16 Phil., 336). The Court reversed the trial court’s judgment and ordered the defendants to pay the plaintiff the sum of P462, with 1% monthly interest from August 19, 1927, until fully paid, in proportion to their shares, with costs against the appellees.