Adamo Estate

82 Pa. D. & C. 222, 1952 Pa. Dist. & Cnty. Dec. LEXIS 108
CourtPennsylvania Orphans' Court, Allegheny County
DecidedJune 13, 1952
Docketno. 1201 of 1951
StatusPublished
Cited by2 cases

This text of 82 Pa. D. & C. 222 (Adamo Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Allegheny County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adamo Estate, 82 Pa. D. & C. 222, 1952 Pa. Dist. & Cnty. Dec. LEXIS 108 (Pa. Super. Ct. 1952).

Opinion

Cox, J.,

The question in this case is whether an executor of a decedent’s estate is relieved by the Fiduciaries Act of 1949 from liability to surcharge where he has made advance distribution from the residuum of the proceeds from the private sale of decedent’s real estate to a devisee whose distributive share is subject to the lien of a judgment entered against him subsquent to decedent’s death and prior to the executor’s sale of the real estate.

Angelina Adamo, also known as Angelina Adams, a resident of Allegheny County, Pa., died testate on November 2, 1950. Her will, dated October 6, 1950, was probated on March 8, 1951, by the Register of Wills of Allegheny County, and on the same date letters testamentary were granted to her son, Jack Adams, also known as Jack Adamo, who was named executor therein. The dispositive provisions of decedent’s will are as follows:

“Second. — I give, devise and bequeath unto my four sons in equal shares after my just debts and funeral expenses are paid, all my real estate, household goods, monies, wearing apparel, personal effects and/or all my possessions. These sons are as follows: John Adamo known as John Adams, Jack Adamo or James Adams known as Jack Adams, Anthony Adamo known as Anthony Adams, Joseph Adamo known as Joseph Adams.”

The only asset in decedent’s estate was a house and lot, which, with the consent of her devisees, the executor sold at private sale, without order of court, for the payment of her debts. The gross sale price was $6,500, and the balance remaining after the expenses [224]*224of the sale was $6,090.48. This sale was consummated on the evening of April 27, 1951, in the law office of Stanton C. Fogie, attorney for the executor. The next day, in the office of Mr. Fogie, decedent’s executor delivered a check in the amount of $800 to Anthony Adamo, one of decedent’s devisees, which was intended to be an advance distribution of the entire share Anthony Adamo would take in decedent’s estate.

Decedent’s executor filed his account on October 11, 1951. At the audit hearing, on December 17, 1951, Joseph Sacco and Theresa Sacco, .through counsel, claimed the entire distributive share of Anthony Adamo in decedent’s estate in the amount of $962.86. This claim is based on a judgment which claimants entered in March 8, 1951, against Anthony Adamo in the Court of Common Pleas of Allegheny County, in the amount of $1,214.86. On June 12, 1951, claimants issued an attachment execution against Anthony Adamo and served it on the executor as garnishee, for the purpose of attaching the distributive share of Anthony Adamo in decedent’s estate. The executor-garnishee, in his answer to the interrogatories, denied that he had any funds in his possession belonging to Anthony Adamo. Nothing further was done in this proceeding prior to the audit of the executor’s account in the decedent’s estate. Since then claimants have discontinued the attachment execution proceeding, and now rely in support of their claim solely on their contention that the judgment entered by them against Anthony Adamo was a lien on the estate he took in decedent’s real estate as a devisee, and that, on the divestiture of his estate therein and claimant’s judgment lien thereon by the executor’s sale of decedent’s real estate, a lien attached on the claimants’ behalf to the distributive share of Anthony Adamo in the residuum of the proceeds from the sale.

[225]*225The executor contends that, by reason of the changes made in the preexisting law relating to the settlement of decedents’ estates by the Fiduciaries Act of April 18, 1949, P. L. 512, the sale of decedent’s real estate divested claimants’ judgment lien on the estate of Anthony Adamo therein, and that the proceeds of the sale became personalty and, having none of the attributes of realty, no lien attached to the distributive share of Anthony Adamo therein on behalf of claimants by reason of their judgment against him. The executor contends further that, after the sale of decedent’s real estate, claimants were in no better position than any other creditor of Anthony Adamo and, in order to perfect a lien against his distributive share in the residuum of the proceeds from the sale of decedent’s real estate, it was necessary for them to issue an attachment execution on their judgment and attach his distributive share in the residuum of the proceeds from the sale in the executor’s hands as garnishee. The executor concludes his argument by asserting that, in the absence of such an attachment, he was privileged to distribute the share of Anthony Adamo or any part thereof in the residuum of the proceeds from the sale of decedent’s real estate to him prior to the filing of an account and its audit by the orphans’ court, and that he is not subject to surcharge because of his having made an advance distribution of $800 to him.

Anthony Adamo was not represented by counsel in this proceeding.

Two basic changes, important to a decision in this case, were made in the preexisting law relating to the settlement of decedents’ estates by the Fiduciaries Act of 1949. The primary liability of a decedent’s personal estate for payment of. his debts and the secondary liability of his real estate for the same purpose were abolished, and both classes of property were made [226]*226equally liable. A decedent’s real estate, as well as his personal estate, was brought within the authority of his personal representative and the jurisdiction of the orphans’ court charged with supervision of the settlement of his estate, regardless of the adequacy of his personal estate for payment of his debts or the absence of a provision in his will authorizing or directing his executor to convert his real estate. These changes were made to facilitate the settlement of decedents’ estates. They were not intended to change the long-established principle of law that a decedent’s entire estate, personal and real, is liable for his debts and only the residuum passes to his heirs, legatees, and devisees (Horner and Roberts v. Hasbrouck, 41 Pa. 169), nor were they intended to change the quantity, quality, or nature of the estate a decedent’s heir or devisee takes in his real estate on his death.

It was for this reason the legislature provided in section 103 of the Fiduciaries Act of April 18, 1949, P. L. 512, that on a decedent’s death the title to his personal estate passes to his personal representative, and in section 104 that title to.his real estate passes to his heirs, or devisees “subject however to all the powers granted to the personal representative by this act and lawfully by the will and to all orders of the Court”. These sections are declaratory of preexisting law and were spelled out by the legislature in order to obviate any question as to the identity of the persons to whom title to a decedent’s personal and real estate passes on his death. The estate which an heir or devisee takes in a decedent’s real estate under the Fiduciaries Act of 1949, therefore, is identical with that which he took under the Fiduciaries Act of June 7, 1917. It is a freehold estate, subject to divestiture by the sale of decedent’s real estate by his personal representative during the settlement of his estate.

[227]*227On the death of Angelina Adamo, therefore, Anthony Adamo took a freehold estate in one fourth of her real estate under the devise to him contained in her will.

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Cite This Page — Counsel Stack

Bluebook (online)
82 Pa. D. & C. 222, 1952 Pa. Dist. & Cnty. Dec. LEXIS 108, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adamo-estate-paorphctallegh-1952.