GR L 8304; (February, 1915) (Digest)
G.R. No. L-8304; February 11, 1915
ARSENIO CAMO, as judicial administrator of the intestate estate of the deceased Claro Crusillo, plaintiff-appellant, vs. JOSE RIOSA BOYCO, defendant-appellee.
FACTS:
Claro Crusillo died on September 3, 1904, survived by his mother as his sole legitimate heir. His brother, Mariano Crusillo, lived with them but had no right to the inheritance. Arsenio Camo was appointed judicial administrator of Claro’s estate. The administrator discovered that three parcels of land, which were the exclusive property of Claro Crusillo as evidenced by perfect titles, were advertised for public auction on March 9, 1909, to satisfy a judgment debt of Mariano Crusillo owed to Jose Riosa Boyco. The administrator filed a notice of intervention with the sheriff, asserting ownership based on Claro’s titles. Despite this, Boyco filed a bond, and the sheriff proceeded with the sale, adjudicating the properties to Boyco. The administrator then filed a complaint to recover the properties. During trial, it was revealed that Mariano Crusillo had declared the lands for tax assessment in his name in 1904 (while Claro was alive) and in 1906. The trial court, applying the principle of estoppel, dismissed the complaint, ruling against the administrator.
ISSUE:
Whether the defendant-appellee, Jose Riosa Boyco, can acquire valid title to the properties through the execution sale based on the tax declarations in Mariano Crusillo’s name, and whether the principle of estoppel applies to bar the recovery of the properties by the lawful owner’s estate.
RULING:
The Supreme Court REVERSED the trial court’s decision.
1. On Estoppel: The Court held that estoppel under Section 333 of the Code of Civil Procedure did not apply. For estoppel to operate, a party must have intentionally and deliberately led another to believe a particular thing true and to act upon such belief. There was no evidence that Claro Crusillo, his estate, or his administrator made any declaration, act, or omission that intentionally induced Boyco to believe the properties belonged to Mariano. Furthermore, Mariano Crusillo, not being a party to the case, could not be estopped. The mere fact that Mariano declared the properties for tax assessment in his name did not constitute the deliberate inducement required by law.
3. On Validity of the Sale: The sale at public auction was declared null and void. The properties, being the exclusive property of Claro Crusillo, could not be levied upon to satisfy the personal debt of his brother Mariano. The lawful owner (now represented by the administrator) must be restored to possession.
4. On Claim for Damages: The Court noted that any claim for damages resulting from the improper execution should be directed against the sheriff, who was not made a party to the case.
DISPOSITIVE PORTION:
The judgment appealed from is reversed. The sale at public auction made to Jose Riosa Boyco is declared null and void. Claro Crusillo is declared the lawful owner of the properties, and the administrator of his estate is to be placed in possession thereof. No costs were awarded.
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