G.R. No. 103737 - Eugenio vs. Court of Appeals

Petitioners: Spouses Isidro and Conrada Salitico, purchasers of the subject land and adverse claimants.
Respondents: Heirs of Resurreccion Martinez-Felix (Luciano, Corazon, Concepcion), Recaredo P. Hernandez as executor of Amanda H. Burgos’s estate, and the Bulacan Register of Deeds.

Amanda H. Burgos owned a 1,413-sqm parcel under Original Certificate of Title No. P-1908 in Bambang, Bulacan; by will (“Huling Habilin,” May 7, 1986), she devised it to her niece Resurreccion.
The will was admitted in probate: approved by RTC Branch 22 on February 6, 2008; Certificate of Allowance issued January 12, 2009; Recaredo appointed executor.

Resurreccion sold her interest to Spouses Salitico by “Bilihang Tuluyan ng Lupa” dated November 10, 1998; the petitioners took physical possession.
Petitioners filed an Affidavit of Adverse Claim (March 17, 2009), which the Register of Deeds denied registration on November 3, 2009.

RTC (Civil Case No. 73-M-2011) dismissed the Complaint for Specific Performance on June 6, 2014 for lack of cause of action, holding the action premature pending full settlement of the estate; Motion for Reconsideration was denied May 26, 2015.
CA (CA-G.R. CV No. 105166) dismissed the appeal on October 19, 2017 due to the pendency of probate proceedings; its Resolution denying reconsideration issued June 7, 2018. Petitioners filed a Rule 45 petition on April 10, 2019.

Whether the Court of Appeals erred in upholding the dismissal of the Complaint for Specific Performance on the ground that the estate of Amanda H. Burgos was not yet fully settled, thereby depriving the petitioners of cause of action.