ALVAREZ VS IAC (GR NO.

68053 | MAY 7, 1990)

CJ Fernan

Aniceto Yanes died and left 2 parcels of land (Lot No. 773 and Lot No. 823) to his heirs (Rufino,
Felipe and Teodora). Teodora cultivated only 3 Ha of Lot No. 823 since she couldnt attend to
the whole property (24 Ha). Rufino and his kids left and did not visit the lands in question until
after the war. One of his children went to the area to get his share after the war, only to be
informed that Santiago, Fuentebella and Alvarez were in possession of Lot 773.

1938 - Santiago was issued TCT for Lot 773-A and Lot 773-B. Both TCT had certification to
eect that the lot was originally registered under OCT No. 8804.

Santiago sold the lots to Fuentebella. After his death, his wife sold the lots in turn to Rosendo
Alvarez.

Two years later, Teodora Yanes + Rufinos children filed with the CFI of Negros Occidental a
complaint against Santiago, Fuentebellas widow, Alvarez and the Register of Deeds of Negros
Occidental for the return of the ownership and possession of Lots 773 and 823.

During the pendency of the case, Alvarez sold the lots to Dr. Rodolfo Siason.

Also during the pendency of the case, Jesus Yanes (one of Rufinos kids), in his own behalf and
in behalf of other plaintis, filed a manifestation renouncing any claim against the widow of
Fuentebella.

CFI Decision (Civil Case No. 5022) - Ordered Alvarez to reconvey the lots to the plaintis.

The execution of the decision was unsuccessful because the lots were in the name of Siason.
The decision couldnt be executed against Siason since he wasnt party to the case.

The Yaneses filed with CFI a petition for the issuance of new certificate of title and for the
declaration of the nullity of the TCTs issued to Alvarez. The court then required Siason to
produce TCTs for the lots in his possession.

- Siason manifested that he bought the lots in good faith, without knowledge of a lien or
encumbrance against the properties

- The court then nullified its order requiring Siason to surrender his TCT

Feb 1968 - The Yaneses filed an action for recovery of real property with damages against
Siason, the heirs of Alvarez and the Register of Deeds.

CFI Decision (1974) - Siason purchased the properties thru an agent as he was in Mexico, so
he was a buyer in good faith for valuable consideration. The Yaneses had been negligent since
they failed to place a notice of lis pendens to protect their rights over the property in question
but equity demanded that they recover the actual value of the land since the sale between
Alvarez and Siason was without court approval.

The Alvarezes appealed to the IAC, which armed the CFI decision insofar as it ordered the
Alvarezes to pay the Yaneses P20K. HtP.

ISSUE (relevant only): W/N the liability or liabilities of Rosendo Alvarez from the sale of the lots
to Dr. Siason could be legally passed or transmitted by operation of law to the petitioners
without violation of law and due process. - YES

GR: Rights and obligations of the deceased are generally transmissible to his legitimate
children and heirs.

Estate of Hemady vs Luzon Surety - The general rule is that a partys contractual rights and
obligations are transmissible to successors.

- Reason: whatever payment made from the estate is ultimately payment by the heirs/
distributees, since the amount of the paid claim diminishes the shares that they will later be
entitled to receive

Such rule is a consequence of the depersonalization of patrimonial rights and duties. Persons
only occupy a representative position, the obligation becoming a transfer of patrimony to
patrimony. Exception is those cases where the obligation is strictly personal.

Application to case: Since petitioners are the heirs of Alvarez, they are still liable for the
consequences of their fathers transaction. They didn't inherit the property, but by legal fiction
the monetary equivalent of it devolved into the mass of their fathers hereditary estate and it
was ruled in previous cases that the hereditary assets are always liable in their totality for the
payment of the debts of the estate.

Petitioners are, however, only liable to the extent of the value of the inheritance.

RULING: CA decision AFFIRMED.