Ozaeta v Palanca (Taxation)

Ozaeta v Palanca G.R. No. L-9776 July 31, 1957 

FACTS:

On May 5, 1955, the special administrator filed a petition in court for authority to pay the accounting firm of Sycip, Gorres, Velayo & Co. the sum of P3,650, for services rendered in taking inventory of assets in 1950, tax consultations in 1950 to 1954, and preparation of income tax returns for 1953 and 1954. The court below denied this motion, on the ground that the services covered by the fees of the accounting firm were rendered to the former special administrator Philippine Trust Company

ISSUE:
whether the services rendered to the special administrator named in the will, previous to his actual appointment as such and at his instance, are chargeable against the estate.

RULING:

Yes.

Whoever may have contracted the services of the accountants, whether it was Mr. Ozaeta before his appointment or the Philippine Trust, such services were for the benefit of the estate and have redounded to the estate's benefit.

The general rule is that acts done by an executor in the interest of his trust, prior to his qualification as such, become binding on the estate upon his qualification

There is no question that the services rendered were for the benefit of the estate. The Rules require that the administrator should submit an inventory of the properties of the estate within three months from his appointment