G.R. No. L-48922. October 30, 1962.
INTESTATE PROCEEDINGS OF THE DECEASED PEDRO ROYO: AMPARO N. VDA. DE ROYO, Administratrix of the Estate of Pedro Royo and PEDRO ROYO JR., movants-appellants, vs. N. T. DEEN and TOMAS DELGADO, oppositors-appellees.

FACTS

This case involves a motion filed in 1940 by the heirs of Pedro Royo to enforce an administrator’s bond against sureties N.T. Deen and Tomas Delgado. The bond was to secure the administration of Pantaleon del Rosario, who had handled the estate’s funds. The movants alleged that Del Rosario failed to account for P17,610.00 from the estate’s assets. The trial court denied the motion.
The record showed that Del Rosario, appointed administrator in 1924, received P43,500.00 from property sales. He accounted for P24,890.00 with receipts, leaving the P17,610.00 balance unaccounted for in the records. However, in a 1928 “Manifestacion,” Del Rosario stated that after arrangements with creditors, the heirs had used most funds, leaving only what was necessary for debts. He indicated the administration held no remaining assets by 1928. The heirs never contested this report during the administration proceedings. Del Rosario died in 1930, and no claim was filed against his own estate for this alleged liability.

ISSUE

Whether the heirs, through the administratrix, can still enforce the administrator’s bond against the sureties after a significant lapse of time and without having previously contested the administrator’s report or filed a claim against the administrator’s own estate.

RULING

The Supreme Court affirmed the denial of the motion, ruling that the action was barred by laches. The legal logic rests on the heirs’ unreasonable delay and failure to act upon knowledge of the alleged deficit. Del Rosario’s 1928 “Manifestacion,” though unsworn, constituted a report on the estate’s status, indicating the funds had been used for debts or given to the heirs. The heirs’ silence for over twelve years—from the 1928 report until filing the motion in 1940—and their failure to object in the probate proceedings or to file a claim in Del Rosario’s own estate settlement, constituted acquiescence. This delay prejudiced the sureties, as it prevented timely verification and defense. The Court applied the principle of estoppel by laches, noting that even if prescription did not strictly apply, equity bars a stale claim where a party neglects to assert a right for an unreasonable length of time. The sureties could rightfully invoke this defense. The Court found no error in the trial court’s reliance on the uncontroverted facts of the 1928 report and the heirs’ prolonged inaction, which negated the existence of any actionable malfeasance by the administrator.