Title
Alcala vs. Pabalan
Case
G.R. No. 6463
Decision Date
Aug 12, 1911
Damasa Alcala sought administratrix appointment for Juan Banatin's property. SC ruled heirs owned undivided property, revoking her appointment as estate was already divided.
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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:

  1. Whether the lower court erred in appointing Damasa Alcala as administratrix of the property, assuming it was still part of Juan Banatin's estate.
  2. 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:

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