GR L 11563; (May, 1959) (Digest)
G.R. No. L-11563; May 29, 1959
ROSITA H. PORCUNA, petitioner, vs. UNITED STATES VETERANS ADMINISTRATION, respondents.
FACTS
Petitioner Rosita H. Porcuna filed a claim in special proceedings No. 18569, seeking payment of P3,710 from the estate of the minors Elena and Dominador Coca. She alleged that from December 20, 1951, to April 30, 1953, she lent this amount to Visitacion Almonte Vda. de Coca, the minors’ mother, for their maintenance, support, and education. The loan was made on the condition that it would be paid from the money due to the minors from the U.S. Veterans Administration (USVA). The Court of First Instance of Manila allowed the claim and ordered the guardian, People’s Bank & Trust Co., to pay it from the wards’ available funds. The Court of Appeals reversed this decision. The records show that during the loan period, the mother received from the USVA a total of P7,245 (from insurance indemnity and gratuity pay) plus a monthly pension, which was more than the P6,360 she testified to having spent on the minors’ support during that time. The guardianship proceedings began on January 15, 1953, and the minors only began receiving direct allowances from the USVA in May 1953.
ISSUE
Whether the estate of the minors Elena and Dominador Coca is legally obligated to pay the loan of P3,710 contracted by their mother, Visitacion Almonte Vda. de Coca, for their support and education.
RULING
No. The Supreme Court affirmed the judgment of the Court of Appeals, dismissing Porcuna’s petition. The Court held that the minors’ estate cannot be made answerable for the loan. First, the mother had a legal obligation to support her minor children and, during the relevant period, she had sufficient funds from the USVA (totaling P7,245 plus a pension) to fulfill this duty without needing to encumber the children’s property. Second, legally, the mother, as the natural guardian of the persons of the minors, had no authority to bind the minors’ estate or their future benefits from the USVA to secure such a loan. Only a judicial guardian of the property (here, People’s Bank & Trust Co.) could do so, and even then, only with prior court approval as required by Rule 96 of the Rules of Court and Republic Act No. 390 . Furthermore, Republic Act No. 360 explicitly exempts USVA benefits from the claims of creditors. Therefore, the loan is a personal liability of the mother and cannot be charged against the wards’ estate or their USVA funds.