G.R. No. 82233 March 22, 1990
JOSE BARITUA and EDGAR BITANCOR, petitioners, vs. HONORABLE COURT OF APPEALS, NICOLAS NACARIO and VICTORIA RONDA NACARIO, respondents.

FACTS

On November 7, 1979, a tricycle driven by Bienvenido Nacario collided with a bus owned by Jose Baritua and driven by Edgar Bitancor, resulting in the death of Bienvenido and damage to the tricycle. No criminal case was filed. Subsequently, the petitioners and their insurer negotiated an extrajudicial settlement with Alicia Baracena Vda. de Nacario, the widow of Bienvenido. On March 27, 1980, Alicia received P18,500.00 and executed a “Release of Claim,” discharging the petitioners and the insurer from all actions arising from the accident. She also executed an affidavit of desistance.
On September 2, 1981, the parents of the deceased, Nicolas and Victoria Nacario (private respondents), filed a complaint for damages against the petitioners. They alleged that during their son’s vigil, the petitioners promised to indemnify them for his death, funeral expenses, and the damaged tricycle, which they claimed to have loaned the purchase price for. The petitioners reneged, settling instead with the widow. The trial court dismissed the complaint, ruling that payment to the widow, a compulsory heir, extinguished the obligation.

ISSUE

Whether the Court of Appeals erred in holding the petitioners liable to the deceased’s parents despite the extrajudicial settlement and release of claim executed by the widow.

RULING

The Supreme Court ruled in favor of the petitioners, reversing the Court of Appeals and reinstating the trial court’s dismissal. The legal logic centers on the proper extinguishment of obligations and the order of succession. Under Article 1231 of the Civil Code, an obligation is extinguished by payment or performance. Article 1240 provides that payment should be made to the person in whose favor the obligation is constituted, their successor-in-interest, or any authorized person.
The Court clarified that under Articles 887 and 985 of the Civil Code, the compulsory heirs of the deceased are his legitimate descendants and his surviving spouse. The parents succeed only in default of legitimate children or descendants. Since it was established that the deceased was survived by his widow, Alicia, and their child, the parents (private respondents) are not compulsory heirs. Therefore, Alicia, as the widow and natural guardian of their child, was the proper successor-in-interest authorized to receive payment and settle the claim. Her execution of a “Release of Claim” validly discharged the petitioners’ obligation.
The Court further held that the parents’ claims—for the tricycle’s purchase price (allegedly a loan to the deceased) and for funeral expenses they shouldered—are merely money claims against the estate of their son. These are not liabilities of the petitioners, whose obligation was already extinguished by the valid payment to and release from the rightful heir. The estrangement of the widow from the deceased was irrelevant, as it is not a legal ground for disqualification from inheritance.