Laura Alvarez, Flora Alvarez and Raymundo Alvarez v IAC, Jesus Yanes, Estelita Yanes, Iluminada Yanes, Antonio

Yanes
and Rosario Yanes
G.R. No. 68053; 07 May 1990; Fernan, CJ.
Digest prepared by Gertrude Gamonnac
DOCTRINE:
The general rule is that a partys contractual rights and obligations are transmissible to the successors.
FACTS
1. Aniceto Yanes owned lots 823 and 773 with a total area of 24 ha. When he died, he left the 2 lots to his children:
Rufino, Felipe and Teodora. Lot 773 (156,549 sq.m.), the property involved in this case, was registered in the
name of the heirs of Aniceto Yanes under OCT R0-4858 which was registered on October 9, 1917 by the Register
of Deeds in Occidental Negros.
2. The respondents in this case are Anicetos grandchildren. Jesus, Estelita and Iluminada are the children of Felipe
while Antonio and Rosario are the children of Rufino. Jovita, the daughter of Teodora was not a party to the case.
3. According to the records, Teodora cultivated only hectares of lot 823. Rufino and his children, on the other hand,
left the province as a result of the outbreak of WWII and returned only after the liberation. The record does not
show whether the children of Felipe also cultivated some portions of the lots.
4. Respondent Estelita said that when her brother visited the land after the liberation to get their share of the
produced sugar, he was informed that a certain Fortunato Santiago, Fuentebella and Rosendo Alvarez were in
possession of lot 773.
5. It is on record that lot 773 was divided into lots 773-A and 773-B. The TCT of lots 773-A and 773-B were issued in
the name of Fortunato Santiago in 1938. The said TCTs contain a certification that the 2 lots were originally
registered under OCT 8804.
6. Santiago later on sold the 2 lots to Monico Fuentebella for P7,000. Consequently, TCTs for the 2 lots were issued
in Fuentebellas name in 1956.
7. After Fuentebellas death, by virtue of a court order, his wife sold the 2 lots for P6,000 to Rosendo Alvarez. As a
result of the sale, TCTs for the 2 lots were issued in Rosendo Alvarez name in 1958.
8. On May 26, 1960, the Yaneses (respondents in this case) filed a case in the CFI of Negros Occidental for the
return of the ownership and possession of Lots 823 and 773.
9. During the pendency of the case or on November 13, 1961, Alvarez sold the two lots to Dr. Rodolfo Siason for
P25,000. Accordingly, TCTs for the 2 lots were issued to Dr. Siason.
10. The CFI rendered a decision ordering Rosendo Alvarez to reconvey to the Yaneses lots 773 and 823. However, the
decision could not be executed since lots 773-A and 773-B were now in the possession of Dr. Siason who is not a
party to the case. Dr. Siason further contends that he purchased the lots in good faith and for a valuable
consideration without knowledge of any lien or encumbrances.
11. In 1968, the Yaneses filed another action for the recovery of the real property. The lower courts decision stated
that the Yaneses should be allowed to recover the actual value of the land because the sale executed between
Rosendo Alvarez and Dr. Siason was without court approval. The decision of the court stated that Laura, Flora
and Raymundo (petitioners in this case) being the legitimate children of Rosendo Alvarez, who was then
deceased, should pay the Yaneses P20,000 as the actual value of the land plus damages.
12. The petitioners appealed to the IAC which affirmed the lower courts decision hence this case.
ISSUE:
WON the liability of Rosendo Alvarez arising from the sale of Lot Nos. 773-A and 773-B could be legally passed or
transmitted by operation of law to his children (petitioners) without violation of law and due process. YES the liability
can be transmitted
HELD:
The decision of the CA is AFFIRMED
RATIO:
1. As correctly ruled by the CA, it is powerless to review the decision ordering Alvarez to reconvey the lots in
dispute to private respondents. Said decision has long become final and executory because Alvarez or his heirs
failed to appeal the decision.
2. The argument of Alvarez heirs that the liability arising from the sale of Lots 773-A and 773-B made by Rosendo
Alvarez to Dr. Rodolfo Siason should be the sole liability of the late Rosendo Alvarez or of his estate, after his
death, is untenable. SEE ARTICLES 774, 776 and 1311 NCC
3. As explained by JBL Reyes in the case of Estate of Hemady v Luzon Surety Inc.
"Under our law, therefore, the general rule is that a party's contractual rights and obligations are transmissible to
the successors. The rule is a consequence of the progressive depersonalization of patrimonial rights and duties
that, as observed by Victorio Polacco, has characterized the history of these institutions. From the Roman
concept of a relation fromperson to person, the obligation has evolved into a relation frompatrimony to
patrimony, with the persons occupying only a representative position, barring those rare cases where the
obligation is strictly personal, i. e., is contracted intuitu personae, in consideration of its performance by a specific
person and by no other. x x x"
4. Since the petitioners are the heirs of the late Rosendo Alvarez, they cannot escape the legal consequences of
their father's transaction, which gave rise to the present claim for damages.
5. Even if the petitioners did not inherit the property involved herein, by legal fiction, the monetary equivalent
thereof devolved into the mass of their father's hereditary estate. It has been ruled that the hereditary assets are
always liable in their totality for the payment of the debts of the estate.
6. It must, however, be made clear that petitioners are liable only to the extent of the value of their inheritance.