Short answer. Yes, if the Philippine administrator knew of the foreign claim and had a chance to contest it. The court adds a certified list of the perfected foreign claims to the claims proved here for a just, equal distribution, but only if the deceased's foreign property was likewise shared fairly with Philippine creditors.
What the law says
If it appears to the court having jurisdiction that claims have been duly proven in another country against the estate of an insolvent who was at the time of his death an inhabitant of the Philippines, and that the executor or administrator in the Philippines had knowledge of the presentation of such claims in such country and an opportunity to contest their allowance, the court shall receive a certified list of such claims, when perfected in such country, and add the same to the list of claims proved against the deceased person in the Philippines so that a just distribution of the whole estate may be made equally among all its creditors according to their respective claims;
Rule 88, Section 10 — When and how claim proved outside the Philippines against insolvent resident's estate paid. Read the full provision →
Foreign claims can be folded in
Where a Philippine resident dies insolvent and claims have already been duly proven against the estate in another country, those foreign claims are not automatically excluded from the Philippine distribution just because they were proven elsewhere. The court receives a certified list of the claims once perfected abroad and adds it to the claims already proved here. This keeps a single insolvent estate from being distributed twice over as if it were two separate pools of assets, one for local creditors and one that foreign creditors simply cannot reach at all.
Two conditions: knowledge and an opportunity to contest
This folding-in is conditioned on the Philippine executor or administrator having had knowledge of the foreign claims being presented and an opportunity to contest their allowance there, so the estate's local representative is not bound by a distant foreign proceeding it never had any real chance to participate in at all. Without that notice and chance to contest, the local creditors' share could effectively be diluted by claims the estate's own representative never had a fair opportunity to dispute in the first place, which is precisely what this condition is meant to prevent.
The reciprocity condition
The benefit runs only one way if reciprocity is missing: the rule's benefit does not extend to creditors in the other country if the deceased's property found there was not equally apportioned between the creditors there and the creditors residing in the Philippines, according to each one's respective claims and share. In other words, foreign creditors only get to share fairly in the Philippine distribution if Philippine creditors were, in turn, treated fairly with respect to whatever estate property was located in that foreign country — the arrangement is meant to be reciprocal, not a one-way benefit to the foreign claimants.
Related provisions
- Rule 88, Section 10 — When and how claim proved outside the Philippines against insolvent resident's estate paid
- Rule 88, Section 9 — Estate of insolvent nonresident, how disposed of
- Rule 88, Section 11 — Order for payment of debts