Estate of Jose B. Yusay, et al. vs. Ramos

A claim against a decedent's estate filed beyond the period fixed in the notice to creditors is barred by the Statute of Non-Claims, and the pendency of a separate action or proceeding is not a sufficient excuse for the belated filing where the claimant unreasonably allowed many months to lapse after judgment was rendered in the separate proceeding before filing the claim against the estate.

The movants-claimants-appellants were laborers who worked for Jose B. Yusay, who died on September 19, 1969. After his death, the workers filed a claim with the National Labor Relations Commission for their share in the sugar amelioration fund. The estate of Jose B. Yusay was under settlement proceedings before the then Court of First Instance of Iloilo, Branch IV, with Teresita Y. Ramos as administratrix.

The movants-claimants-appellants were laborers working for Jose B. Yusay. After Mr. Yusay's death on September 19, 1969, the workers filed a claim with the National Labor Relations Commission for their share in the sugar amelioration fund. The NLRC office at Iloilo City awarded them P26,907.22 corresponding to their participation in the said fund from the 1968-69 crop year to the 1973-74 crop year but excluding the 1972-73 crop year. The award was affirmed by the National Labor Relations Commission, Second Division, on May 13, 1975, and the decision became final and executory. It could not be enforced, however, because the administratrix of the Yusay estate refused to pay the award.

The late Jose B. Yusay died on September 17, 1969, and the petition for settlement of his estate was published in the Visayan Tribune in its October 6, 12, and 20, 1969 issues. The notice to creditors dated November 26, 1969 was published on December 1, 8, and 15, 1969 issues of the Visayan Tribune. The project of partition was approved on February 5, 1974.

The claim against the estate was filed on January 13, 1976, a period of almost seven years from the first notice of publication to the creditors on December 1, 1969, and a period of almost two years from the approval of the project of partition on February 5, 1974. The claimants alleged that the delay in filing the claim was due to the pendency of their case before the National Labor Relations Commission. The decision of the labor arbiter awarding the appellants a sum of money was promulgated on January 10, 1975, and was affirmed in toto by the National Labor Relations Commission on May 13, 1975. The claim against the estate was filed only on January 13, 1976, one year after the promulgation of the decision or eight months after the same had become final and executory.

• Sufficient Excuse for Delay: The movants-claimants-appellants argued that the delay in filing their claim against the estate was due to the pendency of their case before the National Labor Relations Commission, which should serve as a good excuse for the tardy filing of the claim.
• Discretion of the Court: The appellants argued that it is discretionary upon the Court to grant claims against the estate filed beyond the period fixed by law, and that the lower court erred in disallowing their claim.

• Statute of Non-Claims: The administratrix-oppositor-appellee argued that the claim is barred by the Statute of Non-Claims, as it was filed almost seven years from the notice of publication to the creditors and almost two years from the approval of the project of partition.
• Lack of Due Diligence: The appellee argued that the pendency of the claim before the National Labor Relations Commission is not a sufficient excuse for the belated filing of the disputed claim, and that the appellants unreasonably allowed many months to lapse after judgment was rendered before their claim for money was filed.

• Statute of Non-Claims: Whether the claim against the estate was barred by the Statute of Non-Claims for having been filed out of time.
• Sufficient Excuse for Delay: Whether the pendency of the labor case before the National Labor Relations Commission constituted a sufficient excuse for the belated filing of the claim against the estate.

• Statute of Non-Claims: Yes. The claim was barred by the Statute of Non-Claims, having been filed almost seven years from the notice of publication to the creditors on December 1, 1969, and almost two years from the approval of the project of partition on February 5, 1974.
• Sufficient Excuse for Delay: No. The pendency of the claim before the National Labor Relations Commission was not a sufficient excuse for the belated filing of the disputed claim, as the appellants unreasonably allowed many months to lapse after judgment was rendered before their claim for money was filed.

• Statute of Non-Claims: The Court found that the claim was filed on January 13, 1976, almost seven years from the notice of publication to the creditors on December 1, 1969, and a period of two years from the approval of the project of partition on February 5, 1974. The Court noted that while the courts can extend the period within which to present claims against the estate, even after the period limited has lapsed, such extension could only be granted under special circumstances. Given the law and facts of the case, the action taken by the lower court in disallowing the claim could not be considered an abuse of discretion to justify its reversal.

• Sufficient Excuse for Delay: The Court held that the pendency of the claim before the National Labor Relations Commission was not a sufficient excuse for the belated filing of the disputed claim. The appellants instituted an action with the NLRC after the death of Jose B. Yusay, and they were, therefore, trying to recover money from a deceased person. They had notice of the period within which to file claims against the estate and were aware that settlement proceedings had been going on until a project of partition was approved on February 5, 1974. The decision of the labor arbiter was promulgated on January 10, 1975, and affirmed in toto by the NLRC on May 13, 1975. The claim against the estate was filed only on January 13, 1976, one year after the promulgation of the decision or eight months after the same had become final and executory. The Court held that assuming arguendo that the appellants had a legitimate claim against the estate even after the project of partition had been approved two years earlier, due diligence should have been exercised in notifying the lower court immediately after the favorable judgment was rendered. Absent any showing of excusable negligence, unavoidable mistake, accident, or fraud warranting the interposition of a court of equity, the claim may no longer be allowed.

• Statute of Non-Claims — Claims against a decedent's estate must be filed within the period fixed in the notice to creditors. The Court applied this doctrine to bar the laborers' claim, which was filed almost seven years after the notice to creditors was published and almost two years after the project of partition was approved.
• Extension of Period to File Claims — The courts can extend the period within which to present claims against the estate, even after the period limited has lapsed, but such extension could only be granted under special circumstances. The Court held that the lower court's disallowance of the claim was not an abuse of discretion.
• Due Diligence in Filing Claims — Claimants must exercise due diligence in notifying the court immediately after a favorable judgment is rendered in a separate proceeding. The Court held that the appellants failed to do so, having unreasonably allowed many months to lapse after judgment was rendered before filing their claim against the estate.

• "It is quite true that the courts can extend the period within which to present claims against the estate, even after the period limited has lapsed, but such extension could only be granted special circumstances (De Villanueva v. Philippine National Bank, 9 SCRA 145)." — This passage articulates the rule on extension of the period to file claims against an estate, which is central to the Court's analysis of whether the lower court abused its discretion.
• "We agree with the appellee that the claim is barred by the Statute of Non-claims. The pendency of the claim before the National Labor Relations Commission is not a sufficient excuse for the belated filing of the disputed claim." — This is the ratio decidendi of the case, stating the Court's core holding that the claim was barred and that the pendency of the labor case was not a valid excuse.
• "Absent any showing of excusable negligence, unavoidable mistake, accident or fraud warranting the interposition of a court of equity, the claim may no longer be allowed (Nebraska Wesleyan University v. Bowan, 103 NW 275)." — This passage states the standard for allowing a late-filed claim, which the Court applied to deny the laborers' claim.

• Ignacio vs. Pampanga Bus Co., Inc., L-18936, May 23, 1967 — Cited by the lower court for the proposition that where a money claim still being litigated in a civil action was filed in the intestate proceeding after the expiration of the period fixed in the notice to creditors but before the order of final distribution was issued, the pendency of the civil action was a good excuse for the tardy filing of the claim. The Supreme Court distinguished this case, as the claim here was filed long after the judgment became final.
• Afan vs. Guzman, L-14713, April 28, 1960 — Cited by the lower court for the rule that extension of the period to file claims can be made, but the time is one month from the expiration of such period but in no case beyond the date of entry of the order of distribution.
• De Villanueva vs. Philippine National Bank, 9 SCRA 145 — Cited by the Court for the rule that courts can extend the period to present claims against the estate, but such extension could only be granted under special circumstances.
• De Rama vs. Palileo, 13 SCRA 228 — Cited by the Court for the proposition that due diligence should have been exercised in notifying the lower court immediately after the favorable judgment was rendered.
• Nebraska Wesleyan University vs. Bowan, 103 NW 275 — Cited by the Court for the standard that absent any showing of excusable negligence, unavoidable mistake, accident, or fraud warranting the interposition of a court of equity, the claim may no longer be allowed.

• Statute of Non-Claims — The Court applied this doctrine to bar the laborers' claim against the estate, which was filed almost seven years after the notice to creditors was published and almost two years after the project of partition was approved.

Fernan (Chairman), Feliciano, Bidin, and Cortes, JJ., concurred.