Laura Alvarez v.

IAC, Yanes
May 7, 1990
DOCTRINE:
General rule is party's contractual rights and
obligations are transmissible to the successors.
Under doctrine on general transmissibility of
the rights and obligations of the deceased to his
legitimate children and heirs, the binding effect
of contracts upon the heirs of the deceased
party is not altered by the provision of our
Rules of Court that money debts of a deceased
must be liquidated and paid from his estate
before the residue is distributed among said
heirs (rule 89).
FACTS:
Aniceto Yanes owned 2 parcels of land (lot 773-A
& Lot 773-B). Yanes was survived by his 3
children (Rufino, Felipe, Teodora). Herein, the
private respondents were children of Rufino and
Felipe. Out of the 24 hectares, only 3 hectares
were cultivated by Teodora. As a result of the
outbreak of WWII, Rufino and his children left
the province but after liberation when Rufino
went there to get his share of the sugar produced,
he was informed that Santiago, Fuentebella and
Alvarez were in possession of Lot. Santiago's lot
was sold to Fuentebella. Later on, Fuentebella
sold the lot to Rosendo Alvarez( father of herein
petitioners).
2 years later, Teodora and children of Rufino filed
a complaint before CFI of Neg. Occ. against
Santiago, Fuentebella and rosendo Alvarez for the
“return” of ownership and possession of lot.
During the pendency of the case, Rosendo
Alvarez sold the lot to Rodolfo Siason. CFI
rendered decision in favor of Yanes, and ordered
to deliver the possession of the lot.
HOWEVER, the decision was not executed . The
sheriff stated that the lot had been subdivided and
sold to Siason, and could not be delivered to
Yanes since Siason was “not a party per writ of
execution.”
Yaneses filed an action for recovery of real
property with damages , named defendants were

Siason and the Alvarez( descendants of Rosendo
Alvarez and herein petitioners) ; and prayed for
the cancellation of TCT issued to Siason for being
null and void. Lower Court ordered the Alvarez to
pay the actual value of lot (20K) since the sale
between them and Siason was without court
approval, but the sale was not annulled by the
court.
ISSUE: (may mga issue pa re: estoppel pero di na
siya related)
WON the liability or liabilities of Rosendo
Alvarez arising from the sale of Lots Nos. 773-A
and 773-B of Murcia Cadastre to Dr. Rodolfo
Siason could be legally passed or transmitted
by operations of law to the petitioners without
violation of law and due process .
HELD:
YES. General rule is party's contractual rights
and obligations are transmissible to the
successors. Thus, the contention that the liability
arising from the sale of lots should be the sole
liability of late Rosendo Alvarez or of his estate,
after his death is untenable. Under doctrine on
general transmissibility of the rights and
obligations of the deceased to his legitimate
children and heirs, the binding effect of
contracts upon the heirs of the deceased party
is not altered by the provision of our Rules of
Court that money debts of a deceased must be
liquidated and paid from his estate before the
residue is distributed among said heirs (rule
89). The reason for this is, whatever payment is
made from the estate is ultimately a payment by
the heirs since the amount of the paid claim in
fact diminishes or reduces the shares that the heirs
would have been entitled to receive.
Petitioners being the heirs of the Late Rosendo
Alvarez cannot escape the legal consequences
of their father's transaction, which gave rise to
the present claim for damages. The hereditary
assets are always liable in their totality for the
payment of the debts of the estate.
The heirs are only liable to the extent of the
value of their inheritance.

Firstly. ISSUE: Whether or not Johnny Rabadilla is not obliged to comply with the terms of the Will left by Aleja Belleza. that the said land may only be encumbered. the naked ownership shall transfer to Dr.855 square meters of land in Bacolod with the following conditions: 1. shall continue delivering the fruits to Maria Belleza. Held: Johnny is obliged to comply with the terms of the Will left by Aleja. successional rights are transmitted from the moment of death of the decedent and compulsory heirs . Johnny failed to comply with obligation to deliver the fruits of the land. 4. the near descendants. Johnny mortgaged the lot to PNB. As a general rule. Maria Belleza brought a complaint before RTC Bacolod alleging that the heirs of DR. during the lifetime of said Maria Belleza. thus Maria prayed for the reconveyance of the Lot to the surviving heirs of Aleja In his defense. Rabadilla shall die before Maria Belleza. second. Rabadilla. since Aleja had no near descendants at the time of his death. 25 piculs of domestic sugar) 3. no can substitute Dr.6. Jorge Rabadilla was named as a devisee of 511. or sold only to a relative of Belleza. Rabadilla. Rabadilla on the obligation to deliver the fruits of the devised land. Dr. 2. hence. Dr. belleza DOCTRINE: FACTS: In the last will and testatment of Aleja Belezza. sister of Aleja. he shall deliver the fruits of said land to Maria Belleza. Rabadilla vs CA. mortgaged. Jorge violated the conditions. (75 piculs of export sugar. Johnny avers that the term “near descendants” in the will of Aleja pertains to the near descendants of Aleja and not to the near descendants of Dr. that in case Dr. Jorge died in 1983 and was survived his wife and children (Johnny Rabadilla).

Marlena Coscolluela Belleza. The “near descendants” being referred to in the will are the heirs of Dr. Jorge Rabadilla. corollarily. It is likewise clearly worded that the testatrix imposed an obligation on the said instituted heir and his successors-in-interest to deliver one hundred piculs of sugar to the herein private respondent. not extinguished by his death. Hence. the obligations imposed by the will on the deceased Dr. were likewise transmitted to his compulsory heirs upon his death. In the interpretation of Wills. at the time of his death. Rabadilla when Aleja died. It can be gleaned unerringly that the testatrix intended that subject property be inherited by Dr. His failure to do so shall give rise to an obligation for him to reconvey the property to the estate of Aleja. as to the application of any of its provisions. his compulsory heirs succeeded to his rights and title over the said property. Jorge Rabadilla. inheritance includes all the property. Rabadilla. It is clear therefore. Jorge Rabadilla. And since obligations not extinguished by death also form part of the estate of the decedent. that Johnny should have continued complying with the terms of the Will. the testator's intention is to be ascertained from the words of the Will. widow) are called to succeed by operation of law.(legitimate children. rights and obligations of a person. Ownership over the devised property was already transferred to Dr. . taking into consideration the circumstances under which it was made. THUS. and they also assumed his (decedent's) obligation to deliver the fruits of the lot involved to herein private respondent. ownership over the same property was transmitted to Johnny Rabadilla by virtue of succession. Jorge Rabadilla had by virtue of will were transmitted to his forced heirs. 776. Such construction as will sustain and uphold the Will in all its parts must be adopted. when Dr. Upon the death of Dr. Under Art. during the lifetime of the latter. whatever rights Dr. when an uncertainty arises on the face of the Will. Rabadilla himself died.