GR L 68053; (May, 1990) (Digest)
G.R. No. L-68053 May 7, 1990
LAURA ALVAREZ, FLORA ALVAREZ and RAYMUNDO ALVAREZ, petitioners, vs. THE HONORABLE INTERMEDIATE APPELLATE COURT and JESUS YANES, ESTELITA YANES, ANTONIO YANES, ROSARIO YANES, and ILUMINADO YANES, respondents.
FACTS
The case involves Lots 773-A and 773-B, originally part of Lot 773 registered under OCT No. 8804 in the name of the heirs of Aniceto Yanes. Private respondents are Aniceto’s grandchildren. The lots were subsequently transferred to Fortunato Santiago, then to Monico Fuentebella, and later to Rosendo Alvarez, the petitioners’ predecessor. In 1960, some of the Yanes heirs filed an action for recovery of ownership and possession. The trial court ordered Alvarez to reconvey the lots. However, before this decision, Alvarez had already sold the lots to Dr. Rodolfo Siason, who was not a party to the suit, hindering execution.
Private respondents then filed a new complaint for damages against Siason and the Alvarez heirs. The trial court held Siason and the Alvarez heirs solidarily liable for the value of the lots. The Intermediate Appellate Court modified this, absolving Siason as a purchaser in good faith and for value, but affirming the liability of the Alvarez heirs. It ordered them to pay the actual value of the lots, deleting awards for other damages.
ISSUE
Whether the heirs of Rosendo Alvarez can be held liable for the value of the properties their predecessor had sold to an innocent third party, despite not having inherited the specific properties.
RULING
Yes. The Supreme Court affirmed the Appellate Court’s decision, clarifying the extent of the heirs’ liability. The core legal principle is that an obligation to pay damages arising from a breach of contract or an actionable wrong survives the death of the obligor and binds his estate. The nature of an obligation, as a rule, is a relation from patrimony to patrimony, not strictly personal. The act of Rosendo Alvarez in selling property he was later ordered to reconvey created an obligation for indemnity. This obligation was transmitted to his heirs upon his death as a charge against his hereditary estate.
The fact that the heirs did not inherit the specific parcels of land is immaterial. By legal fiction, the monetary equivalent of those properties formed part of the mass of the estate. The hereditary assets are always liable for the debts of the estate. Consequently, petitioners, as heirs, are liable for their father’s obligation, but only to the extent of the value of the inheritance they received. The Court noted the petitioners’ admission that other estate properties were sufficient to cover the adjudged amount, thus upholding their liability for the actual value of the lots as determined by the lower court.