G.R. No. L-18034 - Buenaventura vs. Ramos

Case Citation: 43 Phil. 704; G.R. No. 18034
Date of Decision: September 02, 1922
Petitioners: Sinforoso Buenaventura, as Administrator of the Estate of Juan Buenaventura, Deceased; Timoteo Del Rosario
Defendants: Tomas B. Ramos et al.

On January 4, 1921, Sinforoso Buenaventura filed a petition to sell a fishery belonging to the estate of Juan Buenaventura due to its poor condition, lack of funds for repairs, and the numerous heirs' inability to maintain it.
The heirs opposed the petition on February 5, 1921, leading to the court's initial denial on February 7, 1921, based on several grounds including the lack of an inventory and pending litigation against a tenant, Santos Chua Hong.

Renewed Petition: On February 21, 1921, the administrator renewed the petition. The court eventually granted permission to sell on March 2, 1921, with conditions.
Opposition to Sale: The heirs opposed the sale, arguing it was contrary to legal provisions and the wishes of the majority of the heirs.
Offers: The administrator reported two purchase offers on March 15, 1921, and recommended accepting Timoteo Del Rosario's offer of P11,000.
The court authorized the sale on March 30, 1921, despite continued opposition from the heirs.

The heirs filed for dismissal of the appeal on the grounds of procedural inaccuracies regarding the appeal bond, which was not filed timely.
The Supreme Court addressed the procedural concerns, noting that subsequent motions based on previously existing grounds should not be entertained unless permission was obtained.

Legal Framework: Governed by Sections 714 to 722 of Act No. 190.
Conditions for Sale:
- The administrator may sell property if:
  - Necessary to pay debts and charges against the estate.
  - Sale is beneficial to the heirs.
Requirement for Consent: Written consent from heirs is mandatory for sale of real estate unless for personal property to pay debts.

Key Point: The petition did not specify any unpaid debts against the estate, making the grounds for sale insufficient.
Heirs' Rights: Heirs become owners immediately upon the death of the ancestor and can only be deprived of their rights through the law.

Limitations: The administrator has no authority to sell property without the heirs' consent if there are no debts or obligations against the estate.
Responsibility of Heirs: Heirs manage the property and decide on repairs after becoming absolute owners, free from administrator interference.

The lower court erred in allowing the sale as the necessary legal conditions were not met.
The appeal was upheld, reversing the lower court's decision and absolving the defendants from liability.