G.R. No. L‑4878
February 27, 1909

—

FACTS
– The intestate estate of Joaquina Mijares de Fariñas (deceased) was administered by Enrique de la Vega.
– Heirs of Paulino Lavín filed two claims before the estate commissioners:
1. A debt allegedly owed by José Fariñas (the deceased’s husband) to Paulino Lavín.
2. A debt allegedly owed by the deceased herself to Paulino Lavín.
– The commissioners dismissed both claims; the Court of First Instance allowed the first claim (debt of José) and disallowed the second (debt of Joaquina).
– Documents dated 17 Mar 1886 show José Fariñas receiving ₱971 and ₱200 from Paulino Lavín as capital contributions to a partnership; they do not evidence a creditor‑debtor relationship.
– Joaquina’s 30 May 1889 indorsement merely acknowledged the truth of those receipts, not any indebtedness of her husband.
– In an executive action (10 Oct 1894) Joaquina was asked whether she admitted the contents of a document stating she had received ₱1,233.14 from Paulino Lavín after her husband’s death. She affirmed the receipt but denied recognizing the signature, indicating confusion rather than admission of a debt of her husband.
– A later answer (un‑signed) claimed her husband owed ₱1,171, but this was not admissible as her declaration.
– The purported 20 Jan 1906 will of Joaquina contains no admission that her husband owed Lavín; it merely states her own indebtedness for losses incurred in continuing a government contract.
– Vicente Lavín, appointed judicial administrator of Paulino Lavín’s estate on 5 Mar 1907, pursued the claim. The defendants argued he lacked standing because he had not presented the claim before the commissioners.

ISSUES
1. Whether the documents and Joaquina’s acknowledgments constitute a valid acknowledgment of a debt owed by José Fariñas to Paulino Lavín, thereby interrupting prescription under Art. 1973 Civil Code.
2. Whether the claimant (heirs/administrator) is entitled to recover the alleged debt despite the lack of a clear admission by the deceased or her husband.
3. Whether Vicente Lavín, as judicial administrator, has standing to sue on behalf of the estate notwithstanding his later appointment.

RULING
– The Court held that the 1886 receipts did not create a creditor‑debtor relationship; they merely evidenced a partnership capital contribution. Joaquina’s 1889 indorsement did not acknowledge any debt of her husband, nor did her 1894 testimony constitute a valid acknowledgment. Consequently, no interruption of prescription arose from those statements.
– The claim for ₱1,233.14 (the amount actually received by Joaquina after her husband’s death) cannot be sustained on the ground that it represents a debt of José Fariñas. The Court therefore reversed the lower court’s allowance of the first claim.
– Regarding standing, Vicente Lavín, as duly appointed judicial administrator, was entitled to sue on behalf of Paulino Lavín’s estate; the objection to his personality was dismissed.
– The Court acquitted the defendant on the second cause of action (debt alleged against the deceased herself) and ordered judgment in favor of the plaintiff (the estate) for ₱1,233.14 with 6 % annual interest from 10 Oct 1894, together with costs.

Disposition: Judgment of the Court of First Instance reversed; plaintiff awarded ₱1,233.14 plus interest and costs; defendant cleared of the second claim.