Narciso v. Mauricio
REITERATIONFacts
The Antecedents: The underlying dispute concerns sales executed by a deceased individual in favor of the defendants. The plaintiffs allege these sales were fictitious, rendering them non-existent rather than merely voidable. The deceased reportedly died intestate, leaving no direct descendants or ascendants. The plaintiffs and defendants are identified as collateral heirs. Procedural History: The case originated with complaints filed by the plaintiffs seeking to have the alleged fictitious sales declared void and to partition the properties left by the deceased. The defendants responded with a demurrer and a motion to dismiss. The lower court, by sustaining these motions, effectively dismissed the plaintiffs' claims. The Petition: The plaintiffs, now appellants, are petitioning the Supreme Court, arguing that the lower court erred in dismissing their case. They contend that their allegations, deemed admitted by the demurrer and motion to dismiss, establish their right as intestate heirs to succeed to the properties and to have them divided among themselves and the defendants. The core of their argument is that the fictitious nature of the sales means the properties remain part of the deceased's estate, subject to intestate succession and partition.
Issue(s)
Whether sales alleged to be fictitious are considered non-existent and can be declared as such by intestate heirs. Whether intestate heirs are entitled to the partition of properties where the deceased allegedly executed fictitious sales.
Ruling
The Court ruled in favor of the plaintiffs-appellants, holding that the sales alleged to be fictitious are indeed non-existent and that the intestate heirs are entitled to have these sales declared void and to seek the partition of the properties left by the deceased.
Ratio Decidendi
On Whether Fictitious Sales are Non-Existent and Can Be Declared Void by Intestate Heirs: The Court held that inasmuch as the complaints alleged that the sales executed by the deceased in favor of the defendants were fictitious, and this allegation was deemed admitted by the demurrer and the motion to dismiss, it necessarily follows that said sales are non-existent, not merely null. Therefore, there is nothing to be annulled by action, as the sales are considered as if they never happened. This classification as non-existent is crucial because it means the properties were never legally transferred and remain part of the deceased's estate. On Whether Intestate Heirs Are Entitled to Partition of Properties with Alleged Fictitious Sales: The Court affirmed that inasmuch as the complaints alleged that the deceased died intestate without leaving any descendant or ascendant, and that the plaintiffs and the defendants are her collateral (and therefore intestate) heirs, it necessarily follows that they are entitled to succeed to the properties described in the complaints. These properties should, as sufficiently prayed for by the plaintiffs, be divided among the latter and the defendants in accordance with law. The Court further cited Article 1257 of the Civil Code, which provides that contracts are binding only upon the parties who execute them and their heirs, excepting cases where rights and obligations are not transmissible. When these cases are decided on the merits, it may be necessary to determine the validity of the sales, but this would only be incidental to the main and ultimate relief sought by the plaintiffs, namely, the partition of the properties left by the deceased.
Main Doctrine
When a complaint alleges that sales executed by a deceased person are fictitious, and these allegations are admitted by a demurrer or motion to dismiss, the sales are deemed non-existent, not merely void. Consequently, the intestate heirs of the deceased, who are entitled to succeed to the properties, have the right to have these non-existent sales declared as such and to seek the partition of the properties among themselves and the defendants in accordance with law. This principle is rooted in the Civil Code's provisions on the binding effect of contracts on heirs, which excludes non-transmissible rights and obligations.