G.R. No. L-1489

FACTS:
In the settlement of the estate of Antonio Enriquez, the Court of First Instance of Manila ordered both the former administrator, Francisco Enriquez, and the then administrator, Rafael Enriquez, to render and file their final, sworn accounts of administration. Rafael Enriquez filed a motion alleging that Francisco Enriquez failed to comply with this order, specifically regarding his accounts for the period from 1883 to June 30, 1896. The court found Francisco Enriquez in contempt and sentenced him to imprisonment. Francisco Enriquez appealed.

ISSUE:
Whether or not Francisco Enriquez had submitted his accounts as executor for the period from 1883 to June 30, 1896, thereby complying with the court’s order and rendering the contempt citation erroneous.

RULING:
No, the contempt citation was erroneous. The Supreme Court reversed the judgment of the lower court. The evidence conclusively established that Francisco Enriquez had already submitted his accounts for the contested period. This was demonstrated through a series of public documents and agreements executed among the heirs, particularly documents dated August 25, 1896, and November 20, 1897, which explicitly stated that Francisco Enriquez had presented his accounts from 1884 to June 30, 1896, and that said accounts had been examined and approved by the interested parties. The Court clarified that the issue in the contempt proceeding was not the correctness or final allowance of the accounts, but merely whether they had been submitted for examination. Since submission was proven, there was no basis for the contempt order. The case was remanded with instructions to dismiss the contempt proceeding. No costs were awarded.