G.R. Nos. 244667-69, December 02, 2020
HEIRS OF CORAZON VILLEZA, NAMELY: IMELDA V. DELA CRUZ, I, STELLA IMELDA II VILLEZA, IMELDA VILLEZA III, ROBYL O. VILLEZA AND ABIGAIL WEHR, PETITIONERS, VS. ELIZABETH S. ALIANGAN AND ROSALINA S. ALIANGAN, REP. BY ROGER A. BANANG, RESPONDENTS.

FACTS

The case involves three consolidated complaints for specific performance and damages filed by respondents Elizabeth and Rosalina Aliangan against the heirs of the late Corazon Villeza (petitioners) concerning three parcels of land.
1. Centro I Property (Civil Case No. Br. 20-3009): Respondents alleged that on January 10, 2006, they entered into a Deed of Conditional Sale with Corazon Villeza and Rosario Agpaoa for a residential house and lot. The property was then part of a title under Inocencio Agpaoa but was later issued under Corazon’s name (TCT No. T-356999) on November 14, 2006. Respondents claimed they made monthly remittances to Rosario Agpaoa as partial payments, with Rosario acknowledging receipt of P184,233.00, witnessed and signed by Corazon. They alleged full payment and discovered subsequent deeds of sale (dated February 9, 2007) between Kenneth Agpaoa, Rosario, and Corazon, which they claimed contained forged signatures. Petitioners argued the 2006 Deed was void ab initio because Corazon was not the owner at its execution, payments to Rosario did not bind Corazon, and respondents, as Canadian citizens, were constitutionally disqualified from owning land.
2. Bunay Property (Civil Case No. Br. 20-3010): Respondent Elizabeth alleged that in 2005, Corazon orally offered to sell an agricultural lot to her for P250,000.00. On June 22, 2007, Elizabeth sent two remittances totaling P250,000.00 from Canada, which were received by Corazon. Petitioners denied the existence of an oral contract and argued the remittance receipts were self-serving and hearsay.
3. Poblacion Property (Civil Case No. Br. 20-3011): Respondent Rosalina alleged that in 2000, Corazon orally offered to sell a lot and house to her. From June 2000 to April 2003, Rosalina sent several remittances totaling P307,020.52 from Canada to Corazon as payment. On February 11, 2005, Corazon acknowledged receipt of P85,000.00 as full payment. Petitioners denied the authenticity of the oral contract.
The Regional Trial Court (RTC) rendered three separate Decisions dated August 30, 2016, ruling in favor of respondents. It ordered petitioners to execute the necessary deeds of conveyance for the properties and awarded attorney’s fees. The RTC found the totality of evidence proved the sales, noted respondents (former Filipino citizens) were not disqualified from acquiring land, and found that Elizabeth had re-acquired Philippine citizenship under R.A. No. 9225 .
The Court of Appeals (CA), in its Decision dated December 17, 2018, affirmed the RTC with modification, deleting the awards for attorney’s fees. Petitioners elevated the case via a Petition for Review.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s Decisions which ordered the petitioners, as heirs of Corazon Villeza, to execute deeds of conveyance over the three subject properties in favor of the respondents.

RULING

The Supreme Court GRANTED the petition. The Decisions of the Court of Appeals and the Regional Trial Court were REVERSED and SET ASIDE. The complaints for specific performance were DISMISSED.
The Court held that the actions for specific performance were prematurely filed against the petitioners in their personal capacities. Upon Corazon Villeza’s death, her rights and obligations were transmitted to her estate, not directly to her heirs. The proper party to sue or be sued concerning the decedent’s contracts that survive death is the executor or administrator of the estate, or if none, the estate itself represented by the heirs in a representative capacity under Rule 3, Section 3 of the Rules of Court. The petitioners were sued in their personal capacities as heirs, not as representatives of the estate. Since the estate of Corazon Villeza had not undergone settlement proceedings and no administrator had been appointed, the respondents’ cause of action should have been filed against the estate in a probate or administration proceeding. Filing against the heirs personally was improper.
Given this dispositive ruling, the Supreme Court found it unnecessary to resolve the other substantive issues raised by the parties, such as the validity of the contracts of sale, the citizenship of the respondents, and the sufficiency of evidence. The dismissal was based solely on the procedural ground of prematurity and improper parties.