G.R. No. L-7593, December 24, 1957.
Intestate Estate of the late Florencio P. Buan and Rizalina Paras Buan, deceased. BIENVENIDO P. BUAN and A. NATIVIDAD PARAS, Co-Administrators-appellees, vs. SYLVINA C. LAYA, ET AL., petitioners-appellants.

FACTS

On December 15, 1953, petitioners-appellants (heirs of Juan C. Laya) filed a contingent claim for over P500,000 against the intestate estate of spouses Florencio P. Buan and Rizalina Paras Buan. The claim arose from a collision on August 3, 1952, involving a Philippine Rabbit Bus owned by the deceased spouses, which caused the death of Juan C. Laya and injuries to others. The bus driver, Ernesto Triguero, was convicted of homicide and serious physical injuries through reckless imprudence. Petitioners reserved the right to file a separate civil action for damages and subsequently filed an independent civil action (Civil Case No. 20867) in the Court of First Instance of Manila against the estate’s administrators on October 12, 1953. The contingent claim in the Tarlac estate proceedings was accompanied by a copy of this complaint and the criminal sentence. The administrators opposed the claim, arguing it was not filed before the spouses’ death on January 3, 1953, nor within the period prescribed by Rule 89, Section 4 of the Rules of Court. The Court of First Instance of Tarlac initially admitted the contingent claim on December 16, 1953, but denied the prayer to set aside a portion of the estate to answer for it. Upon motion for reconsideration by the administrators, and after the Manila court (in an order dated November 25, 1953) held the civil action premature because the driver’s conviction was not final and ordered an amended complaint (which was filed on December 18, 1953), the Tarlac court set aside its December 16 order on January 7, 1954, dismissing the contingent claim. Petitioners’ motion for reconsideration was denied, prompting this appeal.

ISSUE

Whether the Court of First Instance of Tarlac erred in dismissing the contingent claim filed by petitioners-appellants against the intestate estate.

RULING

Yes. The Supreme Court set aside the order of dismissal. A contingent claim is one dependent on an uncertain future event for its validity or existence; it may or may not become enforceable. The petitioners’ claim depended on the outcome of their independent civil action for damages in Manila. The dismissal of the contingent claim based on the Manila court’s interim order (holding the civil action premature and requiring an amended complaint) was an incorrect conception of a contingent claim’s nature. A contingent claim is not affected by temporary procedural orders in the underlying action; it awaits the final outcome of that action. Under the Rules (Sections 5 and 9, Rule 87), a contingent claim should be presented in administration proceedings like any ordinary claim, and the court should be informed when the contingency matures. The Supreme Court ordered the contingent claim to be allowed to continue and directed the lower court to fix an amount from the estate to be set aside to answer for any damages petitioners may ultimately recover in the Manila case. The validity of the contingent claim was apparent given the driver’s conviction for negligence, making the estate potentially liable as employer under the principle of respondeat superior.