ALVAREZ v.

IAC, YANES 5022 stating that the therein plaintiffs "renounce, forfeit and quitclaims any
May 7, 1990 | Fernan, C. J. | Inheritance – Contractual Obligations claim, monetary or otherwise, against the defendant Arsenia Vda. de Fuentebella
Digester: Tan, Raya Grace in connection with the aboveentitled case."
 CFI ordered Rosendo Alvarez to reconvey to the plaintiffs Lots 773 and 823
SUMMARY: Lots 773 and 823 were registered under the name of the heirs of and to deliver the possession of said lots to the plaintiffs. Above-mentioned
Aniceto Yanes. After the Japanese war liberation, they found out that the Santiago, manifestation of Yanes was not mentioned.
Fuentebella and Alvarez were in possession of Lot 773. The Yaneses filed a  Execution of the decision was unsuccessful because Lot 773 had been
complaint for the return of the ownership and possession. During the pendency of the subdivided to 773-A and 773-B, and were in the name of Dr. Siason who was
case, Alvarez sold it to Siason who purchased it in good faith and for a valuable not a party per writ of execution.
consideration. CFI ordered Alvarez to reconvey the lots and to deliver the possession  The Yaneses filed a petition for the issuance of a new certificate of title and
to the Yaneses. However, the decision was not executed because Lot 773 had been for the declaration of nullity of the TCTs issued to Alvarez, and also to
subdivided and titles were in Siason’s name. CFI ordered Rosendo Alvarez to require Siason to product the TCTs covering the lots.
reconvey to the plaintiffs Lots 773 and 823 and to deliver the possession of said lots  Siason argued that he purchased the lots in good faith and for a valuable
to the plaintiffs; Siason was a buyer in good faith for a valuable consideration. IAC consideration (P25,000) without any knowledge of any lien or encumbrances
affirmed the liability of defendants to pay jointly and severally but reversed the against said properties; that the decision cannot be enforced against him because
award for damages. SC affirmed IAC ruling. he was not a party-litigant and because it had long become final and executory.
DOCTRINE: Under our law, the general rule is that a party’s contractual rights and  The Yaneses then filed an ex-parte motion for issuance of an alias writ of
obligations are transmissible to our successors. The rule is a consequence of the execution which the lower court ruled cannot be enforced against Siason.
progressive “depersonalization” of patrimonial rights and duties, i.e. instead for a  They then filed for recovery of property for damages against Siason,
relation from person to person, the obligation has evolved into a relation from Alvarez(es) and Register of Deeds of Negros Occidental.
patrimony to patrimony with the persons occupying representative position.  CFI held that Siason was a buyer in good faith for a valuable consideration.
Although the Yaneses were negligent in their failure to place a notice of lis
FACTS: pendens, equity demanded that they recover the actual value of the land because
 Lots 773-A and 773-B were originally known as Lot 773 of the cadastral survey the sale was without court approval.
of Murcia, Negros Occidental, registered under the name of the heirs of Aniceto  IAC affirmed the lower court's decision "insofar as it ordered defendants-
Yanes (children Rufino, Felipe and Teodora) under OCT No. RO-4858. appellants to pay jointly and severally, and reversed insofar as it awarded the
 Private respondents Estelita, Iluminado and Jesus are children of Rufino while sums of P2,000, P5,000 and P2,000. as actual damages, moral damages and
Antonio and Rosario are children of Felipe. Teodora’s child, Jovita, was not attorney's fees, respectively. MR denied.
included as a party in the case.
 Aniceto left his children Lots 773 and 823. Teodora cultivated only 3ha of the RULING: CA affirmed. Petition is devoid of merit. Costs against petitioners.
24-ha lots. According to Estelita, they did not visit the parcels of land during the
Japanese war but when her brother went after liberation, he was informed that WoN the defense of prescription and estoppel had been timely and properly
Santiago, Fuentebella and Alvarez were in possession of Lot 773. invoked and raised by the petitioners in the lower court. – NO
 Santiago was issued a TCT covering Lot 773-A and then later Lot 773-B. He  Decision had long become final and executory; Alvarez or his heirs failed to
sold the lots to Fuentebella, Jr. Administratirix of Fuentebella sold the lots to appeal the decision against them. Note the possible exception of Siason, who
Alvarez. was not a party to the case.
 May 26, 1960 Teodora Yanes and the children of her brother Rufino filed a  When a right or fact has been judicially tried and determined by a court of
complaint for the return of the ownership and possession of lots 773 and competent jurisdiction, so long as it remains unreversed, it should be conclusive
823. upon the parties and those in privity with them in law or estate.
 During the pendency of the case, Alvarez sold Lots 773-A and 773-B to Dr.
Siason, without lis pendens annotated on the titles (held to be a purchaser in WoN the causes of action are barred by prescription and estoppel – NO.
good faith)  Defenses of prescription and estoppel have not been properly considered by the
 November 6, 1962 Jesus Yanes, in his own behalf and in behalf of the other lower court. They could have appealed in the former case but they did not. They
plaintiffs, and assisted by their counsel, filed a manifestation in Civil Case No. have therefore foreclosed their rights, if any, and they cannot now be heard to
 complain in another case in order to defeat the enforcement of a judgment which  Art. 774. Succession is a mode of acquisition by virtue of which the property,
has longing become final and executory. rights and obligations to the extent of the value of the inheritance, of a person
 The sole remedy of the landowner whose property has been wrongfully or are transmitted through his death to another or others either by his will or by
erroneously registered in another's name is to bring an ordinary action in the operation of law.
ordinary court of justice for reconveyance or, if the property has passed into the  Art. 776. The inheritance includes all the property, rights and obligations of a
hands of an innocent purchaser for value, for damages. person which are not extinguished by his death.
 Art. 1311. Contract stake effect only between the parties, their assigns and heirs
WoN the late Rosendo Alvarez (father of petitioners) became privy and/or party except in case where the rights and obligations arising from the contract are not
to the waiver of Yaneses’ rights and interests on Lots 773-A and 773-B. – NO. transmissible by their nature, or by stipulation or by provision of law. The heir is
not liable beyond the value of the property received from the decedent.
[RELEVANT ISSUE] WoN the liabilities of Rosendo Alvarez arising from the
sale of the lots could be legally passed or transmitted by operations of law to the
petitioners without violation of law and due process – YES.
 Such contention is untenable for it overlooks the doctrine obtaining in this
jurisdiction on the general transmissibility of the rights and obligations of the
deceased to his legitimate children and heirs. (See notes for relevant articles).
They cannot escapte the legal consequences
 As heirs, petitioners cannot escape the legal consequences of their father's
transaction, which gave rise to the present claim for damages. That petitioners
did not inherit the property involved herein is of no moment because by legal
fiction, the monetary equivalent thereof devolved into the mass of their father's
hereditary estate, and we have ruled that the hereditary assets are always liable
in their totality for the payment of the debts of the estate. However, they are
liable only to the extent of the value of their inheritance.
 In Estate of Hemady vs. Luzon Surety Co., Inc.:
The binding effect of contracts upon the heirs of the deceased party is not altered by
the provision of our Rules of Court that money debts of a deceased must be
liquidated and paid from his estate before the residue is distributed among said heirs
(Rule 89). The reason is that whatever payment is thus made from the state is
ultimately a payment by the heirs or distributees, since the amount of the paid
claim in fact diminishes or reduces the shares that the heirs would have been
entitled to receive.

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

NOTES: