G.R. No. L-9620 June 28, 1957
In Re Guardianship of the Minor Roy Reginald Lelina. SEVERO VILORIA, guardian and oppositor-appellee, vs. ADMINISTRATOR OF VETERANS AFFAIRS, petitioner-appellant.

FACTS

In Special Proceedings No. 163 of the Court of First Instance of La Union, appellee Severo Viloria was appointed guardian of the person and estate of the minor Roy Reginald Lelina, a beneficiary of arrears pay, insurance, and other benefits from the U.S. Veterans Administration due to the death of his father Constancio Lelina. The court authorized the guardian to withdraw a monthly allowance for the ward’s support. On March 20, 1952, the U.S. Veterans Administration filed a motion alleging that the minor’s deceased father had no recognized guerrilla or other service in the U.S. armed forces and was not entitled to National Service Life Insurance benefits, praying that the guardian be ordered to stop further monthly allowances. The court granted this motion. Later, on February 15, 1955, the Administrator of Veterans Affairs filed a motion for a refund of $2,879.68, the balance of insurance benefits allegedly wrongfully paid, which was on deposit with the Philippine National Bank. The guardian opposed, submitting evidence of the father’s service record recognized by both the Philippine and U.S. Armies, and the motion for refund was denied. Subsequently, the guardian moved to withdraw P4,000 from the estate for the minor’s needs. The Administrator opposed, citing the U.S. Code (Title 38, section 808), which makes decisions of the Administrator final and conclusive, and prayed for the setting aside of the order denying the refund on the ground of “lack of jurisdiction.” The lower court denied both the guardian’s motion to withdraw and the Administrator’s motion for refund, maintaining the status quo of the funds until the issue of the father’s military service is determined in an appropriate action. The Administrator sought reconsideration, which was denied, prompting this appeal.

ISSUE

Whether the Philippine court lacks jurisdiction to adjudicate the claim for refund of benefits filed by the Administrator of Veterans Affairs in the guardianship proceedings, given the U.S. Code provision making the Administrator’s decisions final and conclusive.

RULING

The appeal is rejected. The provisions of the U.S. Code invoked by the appellant, which make the decisions of the U.S. Veterans Administrator final and conclusive, apply only to claims properly submitted to him for resolution and are not applicable here, where the Administrator is acting as a litigant seeking a remedy from the Philippine courts. By filing the motion for refund in the guardianship proceedings, the Administrator submitted to the jurisdiction of the Philippine court and cannot dispute its power. The court affirmed that the burden lies on the Administrator to prove the alleged erroneous payment, and the Philippine courts’ determination of the question is binding upon him as upon any other litigant. Furthermore, the claim for refund was not properly filed in the guardianship proceedings, as such proceedings are concerned solely with the ward’s care and custody and the administration of his properties; conflicts regarding ownership or title to the property should be litigated in a separate proceeding. The order of the lower court dated June 22, 1955, is affirmed.