Alvarez v. IAC [May 7, 1990]

·         Aniceto Yanes owned 2 parcels of land Lot 773-A and Lot 773-B.

·         Rufino and his children left the province to settle in other places as a result of the outbreak of World War II. According to Estelita, from the “Japanese time up to peace time”, they did not visit the parcels of land in question but “after liberation”, when her brother went there to get their share of the sugar produced therein, he was informed that Fortunato Santiago, Fuentebella (Puentevella) and Alvarez were in possession of Lot 773.

·         After Fuentebella’s death, Arsenia Vda. de Fuentebella sold said lots for P6,000.00 to Rosendo Alvarez. On May 26, 1960, Teodora Yanes and the children of her brother Rufino filed a complaint against Fortunato Santiago, Arsenia Vda. de Fuentebella, Alvarez and the Register of Deeds of Negros Occidental for the “return” of the ownership and possession of Lots 773 and 823.

·         During the pendency of said case, Alvarez sold the Lots for P25,000.00 to Dr. Rodolfo Siason. CFI rendered judgment ordering defendant Rosendo Alvarez to reconvey to plaintiffs the lots.

Issue: 

·         WON the liability of Rosendo Alvarez arising from the sale of the lots could be transmitted by operation of law to the petitioners without violation of law and due process.

Ruling

·         The doctrine obtaining in this jurisdiction is on the general transmissibility of the rights and obligations of the deceased to his legitimate children and heirs.

·         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 estate 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.

·         Petitioners being the heirs of Alvarez, they cannot escape the legal consequences of their father’s transaction, which gave rise to the present claim for damages.