G.R. No. L-28298 November 25, 1983
ROSITA SANTIAGO DE BAUTISTA, ET AL., plaintiffs-appellees, vs. VICTORIA DE GUZMAN, ET AL., defendants-appellants.

FACTS

Numeriano Bautista died from injuries sustained when the passenger jeepney he was riding in, owned by Rosendo de Guzman and driven by Eugenio Medrano, overturned due to the driver’s negligence. The driver was criminally convicted and ordered to indemnify Bautista’s heirs P3,000.00, but execution of the judgment against him was returned unsatisfied. Rosendo de Guzman died thereafter. The heirs of Bautista first filed a civil case against the heirs of de Guzman, but it was dismissed because the estate of Rosendo de Guzman was under judicial administration and the complaint did not allege the heirs had received any inheritance. This dismissal became final.
Subsequently, the intestate proceedings for Rosendo de Guzman’s estate were concluded, and a project of partition was approved, distributing his assets to his heirs. After the estate proceedings were closed, the Bautista heirs filed this second civil action against the de Guzman heirs. They sought to enforce the subsidiary civil liability arising from the driver’s criminal conviction (the P3,000.00 indemnity) and to claim additional moral, exemplary, and compensatory damages arising from the death.

ISSUE

Whether the plaintiffs-appellees’ money claim for damages, arising from the death of Numeriano Bautista, is already barred for failure to present it during the judicial settlement of the estate of Rosendo de Guzman.

RULING

Yes, the claim is barred. The Supreme Court reversed the trial court’s decision and ordered the complaint dismissed. The legal logic is anchored on the mandatory claim presentation requirements under the Rules of Court for the settlement of a decedent’s estate. The claim against the estate of Rosendo de Guzman is fundamentally a money claim. It comprises two components: the P3,000.00 subsidiary liability stemming from the driver’s criminal conviction, and the claim for additional damages arising from the breach of the contract of carriage.
Both components are money claims that must be presented within the time limit prescribed in the notice to creditors in the testate or intestate proceedings, pursuant to Section 5, Rule 86 of the Rules of Court. The plaintiffs were aware of the intestate proceedings (Special Proceedings No. 1303-P) but failed to file their claim therein. Consequently, their right to enforce this claim against the distributed assets received by the heirs was extinguished upon the closure of the estate proceedings. The defense of res judicata from the first dismissal was not applicable due to a change in circumstance—the closure of the estate. However, the separate and distinct defense of statutory bar under the rules of estate settlement is controlling. Since the claim was not presented in the probate court, it is forever barred, precluding a subsequent direct action against the heirs.