G.R. No. L-57205 December 14, 1981
THE INTESTATE ESTATE OF DOMINADOR DANAN, represented by its Administratrix, ADORACION F. VDA. DE DANAN, and the HEIRS OF THE LATE DOMINADOR DANAN, et al., petitioners, vs. HON. FELIPE V. BUENCAMINO, in his capacity as Presiding Judge of the Court of First Instance of Pampanga, Branch II, Guagua, Pampanga, BENITO MANALANSAN, et al., respondents.

FACTS

Dominador Danan died intestate. In the settlement of his estate, the court ordered creditors to file claims within six months from December 10, 1973. Spouses Benito and Ines Manalansan filed a “contingent claim” on June 12, 1974, for a deficiency judgment of P98,411.17, anticipating a shortfall after foreclosing a mortgage executed by the deceased and his wife. The administratrix, Adoracion Vda. de Danan, admitted the debt but argued the claim was premature. Hearings were set, but the administratrix or her counsel repeatedly failed to appear. The court eventually gave counsel ten days to object to the claimants’ exhibits, but no objection was filed.
Years later, on October 28, 1980, the Manalansans filed a “Motion to Resolve Claim,” now stating the amount due was P294,298.26. The court ordered the administratrix to comment within ten days. She failed to do so. Consequently, on January 3, 1981, the probate court approved the claim for P294,298.26. The administratrix belatedly filed an opposition, challenging the claim as exorbitant and filed out of time. Her motion for reconsideration was denied.

ISSUE

The primary issues were: (1) whether the contingent claim was filed on time; (2) whether the administratrix was afforded due process; and (3) whether the claim was supported by evidence.

RULING

The Supreme Court set aside the probate court’s orders and remanded the case for a full hearing. On the first issue, the Court ruled the claim was timely. While filed two days after the six-month period, the administratrix, by filing an answer and seeking postponements, acquiesced to its entertainment and was thus estopped from raising timeliness belatedly. Furthermore, under Rule 86, Section 2 of the Rules of Court, the court had discretion to allow claims filed within one month after the period, which was complied with here.
On the second and third issues, the Court found a denial of due process. The probate court’s approval of the ballooned claim from P98,411.17 to P294,298.26 without a “full dress hearing” was improper. While the administratrix was given opportunities to contest, her repeated non-appearance did not justify the court’s mere reliance on her failure to object. The staggering increase in the claim’s amount necessitated a thorough, adversarial hearing where the court should actively examine the evidence and computations, using its coercive powers if needed to ensure participation. The order approving the claim lacked any explanation for the final amount, violating basic procedural fairness. The case was ordered remanded for a proper hearing on the merits.