Alvarez v. IAC

LAURA ALVAREZ, FLORA ALVAREZ AND RAYMUNDO ALVAREZ,
VS.
INTERMEDIATE APPELLATE COURT ET AL.
PETITIONERS
GR no. L-68053 May 7, 1990

Fernan, J.
SV: Washington was charged for murder and wanted to present his co-participant in the crime as a
witness and his testimony be used by the defense. Said co-participant has already been convicted
for the same case at a separate trial. Texas laws prohibit the testimony of a co-participant to be
used by the defense.
Held: Testimony should have been admitted. It was part of his right to have compulsory process for
obtaining witnesses in his favour and the state arbitrarily denied him of this when the testimony of
a witness which was relevant to his defense was not allowed to be admitted in court.
1. The real properties involved are 2 parcels of land (Lot 773-A and 773-B; formerly
Lot 773) which was registered in the name of the heirs of Aniceto Yanes under OCT
RO-4868. Yanes was survived by her children, Rufino(deceased, survived by
Estelita, Iluminado and Jesus), Felipe(had 2 children, Antonio and Rosario Yanes,
respondents in this case) and Teodora(survived by child Jovita/o, but not a party in
this case).
2. Aniceto left his children Lots 773 and 823(not really the relevant succession
part). Teodora cultivated only 3 hectares (couldnt handle all of the 24 hectares); it
was not sure whether the children of Felipe cultivated the land but what was
established was that Rufino and his children left the province and settled elsewhere
because of WWII. When Esters brother went to Lot 773, he discovered that
Fortunato Santiago, Fuentabella and Alvarez were in possession of it
3. Santiago was issued TCT covering 773-A, the other half of the lot was registered
under 773-B also in the name of Santiago. These lots were sold to Monico
Fuentabella. After Fuentabella died, the administratrix filed a motion before the CFI
of Negros Occidental requesting authority to sell the 2 lots (773-A and 773-B).This
was granted and the lots were sold to Rosendo Alvarez on April 1, 1958
4. 2 years later (May 26, 1960), Teodora and the children of Rufino filed in the CFI
Negros Occidental a complaint against Santiago, Vda. De Fuentabella, Alvarez and
the register of deeds for the return of the ownership and possession of Lots 773
and 823. An accounting of the produce of the land starting from 1994 was also
prayed for and after approval, their share be delivered to them.
5. During the pendency of the case, Alvarez sold both lots to Dr. Rodolfo Siason. TCTs
were issued
6. CFI ordered Alvarez to reconvey the properties but execution of the decision
proved unsuccessful since the sheriff discovered that the lots were now in the
name of Rodolfo season and could not be delivered to heirs of Aniceto since Siason
was not a party per writ of execution. Teh yaneses filed a petition for the issuance
of a new certificate of title and declare the TCT of Siason as a nullity. Court required
Siason to produce the titles to the lots
a. Siasons answer: the lots were purchased in good faith and for a valuable
consideration without any knowledge of any lien or encumbrance against
the properties.
7. Lower court ruled that the earlier judgment could not be enforced against Siason
because he was not a party in that case
8. Yaneses filed another action for recovery of real property with damages, this time
including Siason as one of the defendants. In the complaint it was prayed for by
the Yaneses that if delivery by Siason to the Yaneses was not possible then Alvarez
and Siason should be made to pay the sum of P45,000.

a. Siason alleged the validity of his titles since it was already passed upon by
the court, hence res judicata.
9. The lower court held among others that Siason is a buyer in good faith and for
value but in order to protect the rights of the YAneses over the property, equity
demands they be paid the value of the land (the heirs of Rosendo Alvarez were
made to pay P20,000; this is the relevant part).
10.The Alvarez appealed to the IAC, but the IAC only affirmed the ruling of the CFI with
regard to the payment of the value of the lots. MR denied
11.Hence, this petition
Issue/s: Whether or not the heirs of Alvarez should be made to pay the value of
the lots? YES
It has long been established that the sole remedy of the landowner whose property has
been wrongfully or erroneously registered in anothers name is to bring an ordinary action
for reconveyance or if the property has passed into the hands of an innocent purchaser
for value, then an action for damages. It is one thing to protect an innocent third party
but it is an entirely different matter when deceit would be rewarded by allowing the
perpetrator to enjoy the fruits of his deed.
Petitioners also alleged that the liability arising from the sale of the lots should be the
sole liability of the late Rosendo Alvarez or of his estate, after his death. This is
untenable; there is a doctrine on the general transmissibility of the rights and obligations
of the deceased to his legitimate children and heirs
Art. 774. Succession is a mode of acquisition by virtue of which the property,
rights and obligations to the extent of the value of the inheritance, of a person are
transmitted through his death to another or others either by his will or by
operation of law.
Art. 776. The inheritance includes all the property, rights and obligations of a
person which are not extinguished by his death.
Art. 1311. Contract stake effect only between the parties, their assigns and heirs
except in case where the rights and obligations arising from the contract are not
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.
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. (JBL Reyes)
General rule: Partys contractual rights and obligations are transmissible to
the successors
This is a consequence of the progressive "depersonalization" of patrimonial rights and
duties.
They also alleged that they didnt inherit the property but the court held that this does
not matter because by legal fiction, the monetary benefits of the sale have been included
in the estate. Hereditary assets are always liable in their totality for the payment of the
debts of the estate. (They are only liable up to the value of their inheritance, but the
deceased owned other properties and are sufficient enough to answer for the liability)
Held: appealed decision AFFIRMED.

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LAURA ALVAREZ, FLORA ALVAREZ AND RAYMUNDO ALVAREZ,

GR no. L-68053 May 7, 1990

and Siason should be made to pay the sum of P45,000.

Held: appealed decision AFFIRMED.

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