G.R. No. L-33187. March 31, 1980.
CORNELIO PAMPLONA alias GEMINIANO PAMPLONA and APOLONIA ONTE, petitioners, vs. VIVENCIO MORETO, VICTOR MORETO, ELIGIO MORETO, MARCELO MORETO, PAULINA MORETO, ROSARIO MORETO, MARTA MORETO, SEVERINA MENDOZA, PABLO MENDOZA, LAZARO MENDOZA, VICTORIA TUIZA, JOSEFINA MORETO, LEANDRO MORETO and LORENZO MENDOZA, respondents.

FACTS

Flaviano Moreto and Monica Maniega, during their marriage, acquired three adjacent lots, including Lot 1496, covered by a certificate of title in the name of “Flaviano Moreto, married to Monica Maniega.” Monica died in 1946. In 1952, Flaviano, without the consent of Monica’s heirs, executed a deed of absolute sale covering “Lot 1495” with an area of 781 square meters in favor of Geminiano Pamplona (petitioner) for P900.00. The certificate of title referenced was in Flaviano’s name, though the property was conjugal. Subsequently, the petitioners constructed improvements on what was later discovered to be a portion of Lot 1496, not Lot 1495. Flaviano died in 1956.
The heirs of Monica (respondents) filed suit, seeking annulment of the sale as to Monica’s one-half conjugal share, declaration of their ownership over that half, redemption, and damages. They argued Flaviano had no right to sell the entire lot after Monica’s death without consent and prior liquidation. The petitioners claimed they were purchasers in good faith relying on the registered title. A relocation survey confirmed a mutual mistake: the deed described Lot 1495, but the intended and occupied subject was a 781-square-meter portion of Lot 1496.

ISSUE

Was the sale executed by Flaviano Moreto over a portion of the conjugal property Lot 1496 valid and binding?

RULING

Yes, the sale was valid in its entirety. The Supreme Court modified the lower courts’ decisions, which had declared the sale valid only as to Flaviano’s one-half share. The legal logic proceeds from the obligations arising from the contract of sale and the rules on succession. The contract of sale between Flaviano and the petitioners was valid. Under Article 1458 of the Civil Code, a vendor obligates himself to transfer ownership and deliver a determinate thing. Article 1495 further binds the vendor to transfer ownership and deliver the object of the sale. While Flaviano could only alienate his own one-half share of the conjugal property after his wife’s death without liquidation, his act created an obligation upon his heirs.
Upon Flaviano’s death, his heirs (the respondents) inherited not only his property rights but also his obligations under the contract of sale, pursuant to Articles 776 and 1311 of the Civil Code. The obligation to deliver the full 781-square-meter area sold was transmitted to the respondents as heirs. They are therefore bound to comply with their predecessor’s contractual obligation in full. The Court affirmed the validity of the entire sale, declaring the petitioners owners of the full 781-square-meter portion of Lot 1496 they occupied. The Register of Deeds was ordered to segregate this area from the title and issue a new certificate in the petitioners’ names.