Heirs of Villeza v. Aliangan
REITERATIONFacts
The Antecedents: Respondents Elizabeth and Rosalina Aliangan alleged that the deceased Corazon Villeza sold three parcels of land to them. Corazon died without executing deeds of conveyance. Respondents filed three separate complaints for Specific Performance and Damages to compel the heirs of Corazon (petitioners) to execute the necessary deeds. Procedural History: The RTC ruled in favor of the respondents, ordering the heirs to execute the deeds of conveyance and pay damages and attorney's fees. The CA affirmed the RTC's decision with modification, deleting the awards for moral and exemplary damages but maintaining the order for the execution of deeds and attorney's fees. Petitioners appealed to the Supreme Court. The Petition: Petitioners argued that the cases were prematurely filed, that respondents should have filed claims against Corazon's estate, that the Deed of Conditional Sale (DCS) was void, and that oral contracts for the other properties were not proven. They also contended that as heirs, they were not bound by Corazon's contracts.
Issue(s)
Whether the CA erred in ruling that there is a perfected agreement of sale between respondents and Corazon. Whether the CA erred in not dismissing the cases for specific performance for lack of cause of action because respondents should have filed their claims against the estate of Corazon under Rules 86 and 87 of the Rules of Court. Whether the CA erred in affirming the Decision of the RTC ordering petitioners to execute deeds of conveyance in favor of respondents.
Ruling
The Supreme Court denied the petition, affirming the CA's decision with modification. The Court held that the DCS was a valid contract to sell, that the oral contracts for the other properties were enforceable due to partial performance and ratification, and that the heirs were bound by the obligations of the deceased.
Ratio Decidendi
On the issue of whether there is a perfected agreement of sale between respondents and Corazon: The Court affirmed the CA's characterization of the Deed of Conditional Sale (DCS) as a contract to sell. This was based on the stipulation that a Deed of Absolute Sale would be executed only upon full payment of the balance. The Court reiterated that in a contract to sell, ownership is not immediately transferred but is reserved until full payment. The Court also noted that even if Corazon was not the registered owner at the time of the DCS's perfection, Article 1434 of the Civil Code allows for the transfer of title by operation of law once the seller acquires ownership, which Corazon did when TCT No. T-356999 was issued in her name. The Court found that the respondents had fully paid the purchase price for the Centro I property, thus entitling them to demand the execution of the deed of absolute sale. On the issue of whether the cases should be dismissed for lack of cause of action and the claim that respondents should have filed claims against Corazon's estate: The Court found the invocation of Rules 86 and 87, and Sections 8 and 9 of Rule 89 of the Rules of Court to be misplaced. Section 8 of Rule 89 presupposes a pending probate proceeding and an appointed administrator, which was not the case here. Furthermore, the Court reiterated that probate courts generally do not have jurisdiction to determine questions of ownership when title is claimed adversely to the estate. Since the petitioners disputed the validity of the conveyances, an ordinary separate action for specific performance, as filed by the respondents, was the proper recourse. The Court clarified that the heirs, by virtue of succession, step into the shoes of the decedent and are not considered third parties to contracts concerning the estate's property. On the issue of whether petitioners can be compelled to execute deeds of conveyance: The Court affirmed that the heirs are bound by the contracts entered into by their predecessor, Corazon, based on Article 1311 of the Civil Code, which states that contracts take effect between the parties, their assigns, and heirs. The Court emphasized that obligations arising from contracts involving patrimonial rights are generally transmissible. The Court found that the oral contracts for the Bunay and Poblacion properties were enforceable due to partial performance and ratification, evidenced by remittances and acknowledgments signed by Corazon. The Court concluded that since the respondents had fully paid the purchase prices, the heirs could be compelled to execute the necessary documents to transfer ownership and deliver possession of the properties, as provided by Article 1357 of the Civil Code.
Main Doctrine
In a contract to sell, the seller reserves ownership until full payment of the purchase price, and upon full payment, the seller is obligated to execute a deed of absolute sale. Heirs are bound by contracts entered into by their predecessors-in-interest, as obligations are generally transmissible, except when intransmissible by nature, stipulation, or law. Oral contracts for the sale of real property, if partially or totally performed, are enforceable despite the Statute of Frauds.