Case Digest (G.R. No. 6463)
Facts:
The case of Damasa Alcala vs. Modesta Pabalan, Procopio Pabalan, Basilio Salgado, and Juan Banay-Banay revolves around a dispute regarding the administration of property left by the deceased Juan Banatin. On June 11, 1910, Damasa Alcala, the widow of Juan Banatin, filed a petition in the Court of First Instance of La Laguna, seeking to be appointed as the administratrix of the property described in her petition. The lower court granted her request, leading to an appeal by the defendants, who were among the seventeen nieces and nephews of Juan Banatin. Juan Banatin passed away on April 23, 1897, leaving behind his widow and numerous heirs. On June 13, 1897, a voluntary agreement was made among the heirs, excluding one niece, to divide the estate, with the exception of a house that was to remain undivided. The agreement stipulated that Damasa Alcala would receive half of the usufruct of the house for her lifetime, while the other half would be shared among the other heirs. Fran...
Case Digest (G.R. No. 6463)
Facts:
Background of the Case
- On June 11, 1910, Damasa Alcala (plaintiff and appellee) filed a petition in the Court of First Instance of La Laguna, seeking to be appointed as administratrix of a property described in her petition.
- The lower court granted her request, prompting the defendants (Modesta Pabalan, Procopio Pabalan, Basilio Salgado, and Juan Banay-Banay) to appeal the decision.
Death of Juan Banatin and Initial Agreement
- Juan Banatin died on April 23, 1897, leaving behind his widow, Damasa Alcala, and seventeen nieces and nephews.
- On June 13, 1897, the widow and sixteen of the seventeen heirs (excluding Tranquilina Banatin) entered into a voluntary agreement to divide the estate of Juan Banatin, except for a specific house described in the petition.
- The house was to remain undivided, with Damasa Alcala receiving half of its usufruct during her lifetime, and the other half distributed equally among the seventeen heirs.
Administration of the Property
- Francisco Salgado, one of the nephews, was appointed to administer the house, collect rents, and distribute half to Damasa Alcala and the other half to the heirs.
- Francisco Salgado failed to pay Damasa Alcala her share, leading to a lawsuit (Alcala vs. Salgado, 7 Phil. Rep., 151) and a judgment against him.
Sale and Repurchase of the Property
- In 1907, half of the undivided property was sold to Macario Decena due to an execution of the judgment.
- On October 22 and 24, 1908, the heirs of Francisco Salgado repurchased the property using funds from four heirs: Modesta Pabalan, Procopio Pabalan, Basilio Salgado, and Juan Banay-Banay.
Recognition of Ownership and Appointment of Administratrix
- On November 25, 1908, thirteen heirs recognized the four heirs as owners of the repurchased half of the property.
- On the same date, sixteen heirs appointed Modesta Pabalan as the new administratrix of the property, replacing Francisco Salgado.
- Modesta Pabalan administered the property, collected rents, and paid Damasa Alcala her share of the usufruct until the commencement of the present action.
Issue:
- Whether the lower court erred in appointing Damasa Alcala as administratrix of the property, assuming it was still part of Juan Banatin's estate.
- Whether the heirs had the right to divide the estate and appoint an administrator for the undivided property.
Ruling:
- The Supreme Court reversed the lower court's decision, revoking the appointment of Damasa Alcala as administratrix.
- The Court held that the property in question was no longer part of Juan Banatin's estate but was instead the undivided property of the heirs, who had the right to appoint an administrator.
Ratio:
- (Unlock)