G.R. No. L-5064 February 27, 1953
Bienvenido A. Ibarle, plaintiff-appellant, vs. Esperanza M. Po, defendant-appellant.

FACTS

The case involves a parcel of land, a conjugal property, owned by spouses Leonard J. Winstanley and Catalina Navarro. Upon Leonard’s death on June 6, 1946, he was survived by his spouse and minor children. On April 15, 1946, the surviving spouse, Catalina Navarro Vda. de Winstanley, sold the entire parcel to spouses Maria and Roberto Canoy. The Canoy spouses subsequently sold the same parcel to Bienvenido A. Ibarle on May 24, 1947. Neither of these deeds of sale was registered. Later, on January 17, 1948, after her appointment as judicial guardian of her children, Catalina Navarro Vda. de Winstanley sold one-half of the land (belonging to the children) to Esperanza M. Po. Ibarle filed an action to annul the deed of sale to Po.

ISSUE

The sole question for determination is the validity of the sale of the one-half portion of the land by Catalina Navarro Vda. de Winstanley to Esperanza M. Po.

RULING

The Supreme Court affirmed the validity of the sale to Esperanza M. Po. The Court ruled that upon the death of Leonard J. Winstanley, the rights to his succession were transmitted instantly to his heirs at the moment of his death. Consequently, one-half of the conjugal property already belonged to the children at that time. Therefore, Catalina Navarro Vda. de Winstanley’s prior sale of the entire property to the Canoy spouses was null and void insofar as it included the children’s share. In contrast, the subsequent sale to Po, made by Catalina with court authority as the children’s judicial guardian, was legal and effective. The non-registration of the prior deeds was immaterial and, in any case, was due to Ibarle’s own opposition. The Court reserved the right of Ibarle and/or the Canoy spouses to bring an appropriate action for damages against Catalina Navarro Vda. de Winstanley.