Heirs of Arturo Reyes v. Socco-Beltran Case Digest

Heirs of Arturo Reyes v. Socco-Beltran, G.R. No. 176474

Facts: Elena Socco-Beltran (Socco) filed an application for Lot No. 6-B, alleging that it was adjudicated in her favor in the extra- judicial settlement of Constancia Socco’s estate, before the Department of Agrarian Reform (DAR). The heirs of Arturo Reyes opposed the application on the ground that Lot No. 6-B was sold by Miguel R. Socco, brother of Socco, in favor of their father, Atty. Arturo Reyes, as evidenced by the Contract to Sell. Issue: Whether or not petitioners have a better right to the subject property over the respondent’s? Ruling: The Court ruled that the petitioner’s could not derive title of Lot No. 6 -B because Miguel R. Socco was not yet the owner of the said lot and was only expecting to inherit the same. The contract was a conditional sale, conditioned upon the event Miguel Socco would actually inherit and become the owner of the said property. The Court, relying on Article 1459 of the Civil Code on contracts of sale, said that, “The thing must be licit and the vendor must have the right to transfer the ownership thereof at the time it is delivered.” The law specifically requires that the vendor must have ownership of the property at the time of it is delivered. Hence, there was no valid sale from which ownership of the property could have transferred from Miguel Socco to Arturo Reyes, since, at the time of the execution, the former was not yet the owner of the same and was only expecting to inherit it. Furthermore, Arturo Reyes, not having acquired ownership of the property, could not have conveyed the same to his heirs.