E. W. White v. Rafael Enriquez

Summary

E.W. White sued Rafael Enriquez and other heirs to recover P5,960 for services as court-appointed special commissioner in estate administration. The heirs had made an extrajudicial property division with a clause assuming estate debts. The trial court awarded full amount, but the Supreme Court modified the judgment, distinguishing between estate debts and administrative expenses. While White's services created administrative expenses rather than hereditary debts, the Court held the heirs jointly liable since they secured his appointment and benefited from his services. Under Civil Code Article 1137, defendants were only liable for their proportionate share since not all heirs were sued, resulting in a P4,288 judgment with interest.