G.R. No. 141634 February 5, 2001
Heirs of Spouses Remedios R. Sandejas and Eliodoro P. Sandejas Sr., represented by Roberto R. Sandejas, petitioners, vs. Alex A. Lina, respondent.

FACTS

Eliodoro Sandejas, Sr. was appointed as the administrator of the intestate estate of his deceased wife, Remedios. During the pendency of the probate proceedings, and without prior court approval, Eliodoro entered into a “Receipt of Earnest Money With Promise to Buy and Sell” with respondent Alex A. Lina, covering four parcels of land forming part of the estate. The contract stipulated a total purchase price of P1,000,000.00, with Lina having already paid earnest money. Eliodoro later passed away. Lina subsequently filed a motion to intervene in the probate case, seeking specific performance of the contract and its approval by the probate court. The heirs of the spouses Sandejas opposed, arguing the contract was void for lack of court approval and for encompassing properties beyond Eliodoro’s share.

ISSUE

The primary issue is whether the contract to sell executed by the administrator without prior probate court approval is valid and binding, and if so, to what extent.

RULING

The Supreme Court, affirming the Court of Appeals, ruled that the contract is valid but binds only the share of the administrator, Eliodoro Sandejas, Sr., in the estate properties. The legal logic is twofold. First, a contract of sale concerning estate property, entered into by an heir or administrator, is not rendered void merely because it is subject to probate court approval. It constitutes a valid conditional contract, binding between the contracting parties, though its efficacy is contingent on securing the requisite judicial sanction. Second, an administrator cannot validly convey property rights belonging to other heirs without their consent. The probate court correctly limited the enforcement of the contract to Eliodoro’s proportionate share in the conjugal estate. Upon Remedios’s death, one-half of the conjugal property belonged to her estate, and the other half belonged to Eliodoro. From the estate’s half, Eliodoro also inherited a share as an heir. The Court computed his total interest at three-fifths (3/5). Consequently, the contract is enforceable only as to this 3/5 portion. Lina was ordered to pay the balance of the purchase price corresponding to this share, and the current administrator was directed to execute the deed of conveyance. The ruling emphasizes that while the probate court has jurisdiction to authorize such sales under Rule 89 of the Rules of Court, the standing to seek authority is not limited to the executor or administrator but extends to any party, like Lina, who stands to be benefited by the contract.