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[GOVERKMENT OF PHIUPPINE ISLANDS v. CEPILLO CRUZ.](https://www.lawyerly.ph/juris/view/c1e95?user=fbGU2WFpmaitMVEVGZ2lBVW5xZ2RVdz09)
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[ G R No. 34152, Dec 15, 1931 ]

GOVERKMENT OF PHIUPPINE ISLANDS v. CEPILLO CRUZ. +

DECISION

G. R. No. 34152

[ G. R. No. 34152, December 15, 1931 ]

THE GOVERKMENT OF THE PHIUPPINE ISLANDS, PLAINTIFF AND APPELLEE, VS. CLARA SANTOS, AS GUARDIAN OF AMBROSIA, LUIS, ANDRES, ROQUE, AND FELISA, ALL SURNAMED CEPILLO CRUZ.

D E C I S I O N

STREET, J.:

This action was instituted by the Attorney-General on behalf of the Government of the Philippine Islands to recover from Clara Santos,  as guardian of Ambrosio, Luis, Andres, Roque, and Felisa,  of the surname Cepillo Cruz, a sum of money alleged to be owing as income tax of their father for the years 1923 and 1925.  Upon hearing the cause the trial court gave judgment for the plaintiff to recover of the defendant the sum of P318.43 as income tax  for the year 1923 and the sum of P710.04 for the year 1925, with the surcharges and interest as fixed by law, with  costs  against the defendant.  From this judgment the defendant guardian appealed on behalf of her wards.

No question is  made as to the fact that for the years mentioned income accrued  against Felix Cepillo Cruz,  the father of the minor defendants,  or against his estate, after his death, in the amount found by the trial court and that said  income taxes have not been paid.   Only two questions of moment are raised in the  appellant's  brief,  which, are,  first,  that the claim should have  been filed with the  commissioners appointed to receive and report  upon claims against  the estate,  and, secondly, that an  action will  not lie  against the heirs, the administrator  being the person primarily chargeable with this obligations.

These two points are fully met by  two decisions of this court.  The.first is  Pineda  vs. Court of First Instance of Tayabas,  27 O.  G. 1272, and the second  is Government of the Philippine Islands vs. Pamintuan,  G. R.  Ho. 33139.  It appears that the property  belonging to the estate of Felix Cepillo Cruz has been  distributed among his  children,  the minor defendants in  this case, who are  hie heirs;  and the propriety of permitting  this action  directly against the guardian of the heirs follows  from that fact.   It is really  an action for equitable contribution from the heirs.  Of course their liability could not be extended  beyond the  amount of the property severally received by them, but no question is made that the  guardian is in possession of ample  means to meet the  obligations.

Furthermore, ample authority for the maintenance of thi3 action is contained in section 731 of the Code of Civil Procedure, a3  interpreted  by this court in Lopez vs. Enriquez, 16 Phil. 336.   Said section clearly recognizes the  obligation of heirs and legatees  who  have come into the possession of property subject to any liability chargeable against the estate of their testator  to contribute ratably, according  to  the amount of property which  has  come into their  hands, to the satisfaction of such liability;  and in  the  last clause  of said section it is said: "and the persons who, as heirs,  have received the estate not disposed of by will, shall be liable to  contribute like the devisees or legatees."

The judgment appealed from will be affirmed, and it is so ordered, with costs against the appellant guardian.

Ten days after the publication of this decision final judgment will be entered, and five days thereafter the record will be remanded to the court below.

JIDGMEITT AFFIRMED .

Avanceña,  C.J., Malcolm, Romualdez, and Imperial,  JJ., concur.

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