G.R. No.: 3236

Parties:
Plaintiff-Appellee: Sebastian Abiera, administrator of the estate of Juan Abiera, deceased
Defendant-Appellant: Miguel Orin

FACTS:
Vicenta Cacao married Miguel Orin and died without descendants or ascendants. In 1898, Miguel Orin, Mariano Cacao, and Juan Abiera entered into a written agreement concerning the disposition of properties and animals acquired during the marriage of Miguel Orin and Vicenta Cacao. Mariano Cacao and Juan Abiera acted as representatives of their children, who were identified as the natural nephews of the deceased Vicenta Cacao and the heirs to her estate. The contract stipulated that Miguel Orin would deliver the sum of 1,000 pesos to each of his brothers-in-law (representing the heirs) by August 15th. The plaintiff, as the special administrator of the estate of his deceased father, Juan Abiera, filed a complaint alleging that the defendant (Miguel Orin) had not complied with the contract and sought to compel compliance. The lower court ruled in favor of the plaintiff, ordering the defendant to pay the claimed sum. The appellate court noted that Juan Abiera entered into the contract not for his own personal right, but as a representative of his children, who were the heirs to the estate of Vicenta Cacao through their deceased mother, Petra Cacao (sister of Vicenta Cacao).

ISSUE:
Does the administrator of the estate of Juan Abiera have the legal standing to sue for the enforcement of a contract executed by Juan Abiera in representation of his children, where the obligation was to his children and not to Juan Abiera personally?

RULING:
No. The Supreme Court reversed the judgment of the lower court and dismissed the complaint. The Court held that the obligation contracted by Miguel Orin was in favor of the children of Juan Abiera, not Juan Abiera himself. Therefore, Sebastian Abiera, as the administrator of Juan Abiera’s estate, had no right of action to demand compliance with an obligation that was not owed to the estate he administered. The right of Juan Abiera to represent his children, whether as father or guardian, was a personal right that extinguished with his death. The administrator’s authority is limited to actions pertaining to the estate being administered, and not to contracts or obligations executed in favor of third persons. The exception regarding the lack of a right of action can be raised at any stage of the case.