Johnny Rabadilla vs Court of Appeals

written by Howard

G.R. No. 113725 – 390 Phil. 11 – 334 SCRA 522 – Civil Law – Succession – Transmissible Obligations

A certain Aleja Belleza died but he instituted in his will Dr. Jorge Rabadilla as a devisee to a 511,855 square-meter land. A condition was however imposed to the effect that:

1. the naked ownership shall transfer to Dr. Rabadilla;

2. he shall deliver the fruits of said land to Maria Belleza, sister of Aleja, during the lifetime of said Maria Belleza;

3. that in case Dr. Rabadilla shall die before Maria Belleza, the near descendants, shall continue delivering the fruits to Maria Belleza;

4. that the said land may only be encumbered, mortgaged, or sold only to a relative of Belleza.

In 1983, Dr. Rabadilla died. He was survived by Johnny Rabadilla.

In 1989, Maria Belleza sued Johnny Rabadilla in order to compel Johnny to reconvey the said land to the estate of Aleja Belleza because it is alleged that Johnny failed to comply with the terms of the will; that since 1985, Johnny failed to deliver the fruits; and that the the land was mortgaged to the Philippine National Bank, which is a violation of the will.

In his defense, Johnny avers that the term “near descendants” in the will of Aleja pertains to the near descendants of Aleja and not to the near descendants of Dr. Rabadilla, hence, since Aleja had no near descendants at the time of his death, no one can substitute Dr. Rabadilla on the obligation to deliver the fruits of the devised land.

ISSUE: Whether or not Johnny Rabadilla is not obliged to comply with the terms of the Will left by Aleja Belleza.

HELD: No. The contention of Johnny Rabadilla is bereft of merit. The “near descendants” being referred to in the will are the heirs of Dr. Rabadilla. Ownership over the devised property was already transferred to Dr. Rabadilla when Aleja died. Hence, when Dr. Rabadilla himself died, ownership over the same property was transmitted to Johnny Rabadilla by virtue of succession.

Under Article 776 of the Civil Code, inheritance includes all the property, rights and obligations of a person, not extinguished by his death. Conformably, whatever rights Dr. Rabadilla had by virtue of the Will were transmitted to his forced heirs, at the time of his death. And since obligations not extinguished by death also form part of the estate of the decedent; corollarily, the obligations imposed by the Will on the deceased Dr. Jorge Rabadilla, were likewise transmitted to his compulsory heirs upon his death. It is clear therefore, that Johnny should have continued complying with the terms of the Will. His failure to do so shall give rise to an obligation for him to reconvey the property to the estate of Aleja.

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