G.R. No. 5262, FRANCISCO ROSA HERNANDEZ, ET AL., plaintiffs-appellees, vs. MELECIO PADUA, ET AL., defendants-appellants., September 18, 1909

FACTS:
Sabino Hernandez, after his wife’s death, pledged a fish pond to Rafael Padua and Dominica de los Santos for P100. Later, Sabino’s children (including Francisco Hernandez, who is now the sole surviving son) received an additional P63, bringing the total debt to P163. Francisco Hernandez and Regina Panso (widow of Sabino’s deceased son, Santos) sought to redeem the fish pond from Melecio and Miguela Padua (children of Rafael and Dominica) by paying the P163.

The defendants admitted the existence of the pledge contract but challenged the plaintiffs’ legal capacity to bring the action as heirs without a prior judicial declaration of heirship. They also claimed reimbursement for P405 in expenses for repairs on the fish pond (P15 per annum for 27 years), in addition to the P163, totaling P568.

The Court of First Instance of Bulacan ruled in favor of the plaintiffs, allowing them to redeem the fish pond upon payment of P163, and dismissed the defendants’ claim for repairs due to lack of certainty and proof. The defendants appealed, primarily questioning the plaintiffs’ legal capacity and the dismissal of their counterclaim for repairs.

ISSUE:
1. Whether a prior judicial declaration of heirship is necessary for heirs to exercise a right of action derived from their deceased parents.
2. Whether the defendants are entitled to reimbursement for alleged repairs on the pledged fish pond.

RULING:
The Supreme Court affirmed the judgment of the Court of First Instance.

1. A prior judicial declaration of heirship is not necessary for the children of a deceased person to exercise rights of action derived from their parents. The Court reiterated that Section 596 of the Code of Civil Procedure supports this doctrine. Furthermore, the plaintiffs’ status as legitimate children and heirs was fully established during the trial, and the defendants’ predecessors (the original pledgees) had even recognized them as successors by accepting additional payments from them. It is immaterial whether the property originally belonged to Sabino Hernandez or Basilia Castro, as the plaintiffs are proven representatives and legitimate heirs.
2. The claim for reimbursement for repairs was correctly dismissed. The evidence presented by the defendants regarding the alleged expenses was “confused and uncertain,” failing to establish with certainty the amount of repairs or that they were indeed made as claimed. Therefore, the lower court did not err in denying the counterclaim for repairs.