Baranda v. Baranda
GR 73275. 20 May 1987
FACTS:
Paulina Baranda died without issue, but before her demise, two of her supposed heirs, the herein respondents Evangelina and Elisa Baranda, have already taken possession of 6 parcels of land and caused the transfer of such by virtue of questionable sales which the late widow had also sought the reconveyance which did not however materialized. The petitioners, siblings of the decedent, now sought the annulment of the supposed sale or transfers. Respondents question the petitioners legal standing, them being not a party-in-interest in the deed of sale.
ISSUE:
Can the petitioners impugn the validity of the sales?
RULING:
Yes. This Court has repeatedly held that “the legal heirs of a decedent are the parties in interest to commence ordinary actions arising out of the rights belonging to the deceased, without separate judicial declaration as to their being heirs of said decedent, provided that there is no pending special proceeding for the settlement of the decedent’s estate.
There being no pending special proceeding for the settlement of Paulina Baranda’s estate, the petitioners, as her intestate heirs, had the right to sue for the reconveyance of the disputed properties, not to them, but to the estate itself of the decedent, for distribution later in accordance with law. Otherwise, no one else could question the simulated sales and the subjects thereof would remain in the name of the alleged vendees, who would thus have been permitted to benefit from their deception, In fact, even if it were assumed that those suing through attorneys-in-fact were not properly represented, the remaining petitioners would still have sufficed to impugn the validity of the deeds of sale.
