Jose T. Paterno v. Catalina Solis

Summary

This case involves a debt collection and lien foreclosure action between estates of deceased parties. Jose T. Paterno, executor of Maximino Paterno's estate, sued Catalina Solis, administratrix of Gregorio Aguilera's estate, to enforce a debt of 237,116.85 pesos Mexican currency with accumulated interest secured by lien on real property. The Supreme Court affirmed the lower court's judgment, rejecting challenges to the executor's legal capacity to sue and upholding the debt amount. The Court clarified that executors appointed jointly and severally with proper authorization can act individually, and that express will provisions can extend executor duties beyond the statutory one-year limit. The decision was modified only regarding currency conversion procedures, requiring compliance with Act No. 1045's evidence-based exchange rate determination rather than using official government rates. The case establishes important precedents on executor authority and estate administration procedures.