## **Facts:**
On January 13, 1980, a vehicular accident occurred on the National Highway, Barangay Agos, Polangui, Albay. A passenger bus owned and operated by Felicidad Balla, driven by Domingo Casin, swerved and collided with a Ford Fiera driven by Ruben Lim Relucio, before colliding with a passenger bus driven by Fabian Prades. This accident resulted in the deaths of Felicidad Balla, Domingo Casin, Ruben Lim Relucio, and Fabian Prades.
On July 4, 1980, the spouses Oscar and Victoria Prades filed a damage suit in the Court of First Instance of Camarines Sur against Felicidad Balla’s children (Ruben, Bella, Arnulfo, Caruso, Anita, Elsie Melgar, and Erlina Melgar Aseco). They asserted the reckless driving of Balla’s driver caused Fabian Prades’ death and claimed Balla’s estate should be liable for damages due to lack of diligence in selecting and supervising her driver.
Petitioners moved to dismiss the case arguing no valid cause of action against them as heirs and insisted that any claims should be directed to Balla’s estate, not them personally. The court denied the motion on September 23, 1980. A motion for reconsideration was filed on September 30, 1980, but was denied on November 11, 1980, alongside the admission of an amended complaint against Balla’s estate as represented by her children.
Consequently, a petition for certiorari was filed with the Supreme Court on December 23, 1980.
## **Issues:**
1. Whether the Court of First Instance has jurisdiction to entertain the damages suit against the estate of Felicidad Balla, represented by her heirs.
## **Court’s Decision:**
The Supreme Court ruled that the Court of First Instance has the power to entertain the suit. The Court explained under Section 1, Rule 87 of the Rules of Court, actions seeking damages for tortious conduct (like the one caused by Balla’s driver) survive the death of the defendant and may be brought against the decedent’s executor or administrator.
However, since no estate proceedings existed due to the heirs’ claim that Balla left no properties, the heirs, in this case, were required to take the place of the deceased in the absence of an estate settlement, judicially or extrajudicially.
The petition was dismissed, and the heirs were ordered to be substituted for the deceased Felicidad Balla.
## **Doctrine:**
– **Actions for damages caused by tortious conduct survive the death of the tortfeasor** and may be brought against the estate, represented by an executor or administrator, or in their absence, the legal heirs.
– **Under Section 17 of Rule 3** of the Rules of Court, in cases where there is unreasonable delay in the appointment of an executor or administrator, or an extrajudicial settlement by the heirs, courts may allow the heirs to substitute the deceased in the suit.
## **Class Notes:**
– **Section 5, Rule 86, Rules of Court**: Enumerates actions that abate by death.
– **Section 1, Rule 87, Rules of Court**: Actions to recover damages for injury or property may be brought against an executor or administrator.
– **Article 1311, New Civil Code**: The heir is not liable beyond the value of the property received from the decedent.
– **Substitution of parties**: Courts can allow heirs to be substituted for the deceased to avoid absences of estate proceedings hindering the course of justice.
## **Historical Background:**
The case exemplifies the Filipino legal system’s handling of civil liability in collision cases involving multiple deaths and resulting damage claims against the deceased’s estate. It highlights procedural issues in estates where no explicit administration has been undertaken by the heirs and provides insights into the Philippine judicial interpretation of obligations and liabilities surviving posthumously in the absence of estate proceedings.
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