Guillermo Bowler v. Pastro Alcazar

Summary

Bowler claimed against the estate of Matea Alvarez based on a 1896 promissory note for P13,915 'without interest.' The Supreme Court held that while the estate owed the principal debt, it was not liable for interest after the debtor's death in 1897. The Court found no agreement for post-maturity interest, noting the note explicitly stated 'without interest' and that prepaid interest included in the note amount only covered the original two-year term. A subsequent 1899 agreement by heirs to pay interest created obligations that arose after death and were outside the commissioners' jurisdiction over estate claims. The decision clarifies that estate commissioners can only consider claims existing at the time of death, establishing important precedent for estate administration procedures.