Case Digest (G.R. No. 125835) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Natalia Carpena Opulencia v. Court of Appeals, petitioner Natalia Carpena Opulencia, one of the heirs of the late Demetrio Carpena, executed on February 3, 1989 a Contract to Sell in favor of private respondents Aladin Simundac and Miguel Olivan covering Lot No. 2125 of the Sta. Rosa Estate in Laguna, measuring 23,766 square meters, at ₱150.00 per square meter. The respondents paid a downpayment of ₱300,000.00. At the time, the Last Will and Testament of Demetrio Carpena was pending probate in the Regional Trial Court, Branch 24, Biñan, Laguna, and the contract expressly stated that the sale awaited “complete clearance of the court on the Last Will.” Petitioner later offered to refund the downpayment upon realizing that probate court approval had not been obtained, but respondents refused. In the trial court, respondents filed a complaint for specific performance, while petitioner admitted the transaction but pleaded its nullity for lack of probate approval and filed a demurr... Case Digest (G.R. No. 125835) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint for Specific Performance
- Private respondents Aladin Simundac and Miguel Oliven alleged that on February 3, 1989, petitioner Natalia Carpena Opulencia executed in their favor a Contract to Sell Lot 2125 of the Sta. Rosa Estate (23,766 sqm) at ₱150.00 per sqm and received a downpayment of ₱300,000.00.
- Respondents prayed that petitioner be ordered to perform her obligations under the contract and pay damages, attorney’s fees, and litigation expenses.
- Petitioner’s Traverse and Demurrer to Evidence
- Petitioner admitted execution of the Contract to Sell and receipt of ₱300,000.00 but asserted:
- The property formed part of the testate Estate of her father, Demetrio Carpena, subject to probate proceedings in RTC, Branch 24, Biñan, Laguna.
- The contract was not approved by the probate court; she offered to return the downpayment, which respondents refused; she faced tenant claims and rescinded the contract.
- At pre-trial, parties stipulated:
- Trial Court Proceedings
- Respondents presented witnesses and documentary evidence: Contract (Exh A), will copy (Exh B), receipts (Exhs C-E), and demand letters (Exhs F-G).
- Petitioner filed a Demurrer to Evidence, contending the contract was void for lack of probate approval and subject to a suspensive condition (probate).
- RTC granted the demurrer and dismissed the complaint, holding sales of estate property by an administrator require prior probate court approval under Sec. 7, Rule 89, Rules of Court, and that an administratrix is not estopped from challenging her own void act.
- Court of Appeals Decision
- CA reversed the dismissal, declaring the Contract to Sell valid and binding, subject to the result of the estate administration.
- CA held that petitioner sold the property in her capacity as an heir-owner (lawful owner) for her own need, not as executrix or administratrix for estate benefit; thus Rule 89 did not apply.
- CA directed that final execution of the deed await completion of the testate proceedings.
- Supreme Court Review
- Petitioner’s sole issue: validity of the contract without probate court approval.
- SC denied the petition, affirmed the CA decision, and found the contract valid as petitioner acted as heir-owner; performance must await settlement of the estate; petitioner estopped from reneging after receipt of downpayment.
Issues:
- Whether the Contract to Sell executed by petitioner without approval of the probate court is valid and binding.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)