Salvador v Sta.

Maria
G.R. No. L-25952, 30 June 1967

Facts: Celestino Salvador executed a deed of sale over two parcels of land in Bulacan to spouses Alfonso Salvador
an Anatolia Halili. However, he soon filed a suit for reconveyance alleging the sale was void for lack of
consideration (Branch I).

On April 27, 1956, Celestino died Testate and 21 persons were substitutes as plaintiffs as his alleged heirs.
Meanwhile, a special proceeding (Branch II) for the probate of hi will and letters testamentary was instituted
wherein Dominador Cardenas was appointed as administrator.

In the reconveyance suit, Branch I rendered judgment ordering defendants to reconvey parcels of land to the estate
of Celestino which was confirmed by the CA however modified it by reconveying the parcels of land to the 21 heirs.

3 years pursuant to the order of Branch II in the testate proceedings, one of the parcels of land (Lot 6) was sold so
that with its proceeds, the debts of Celestino are to be paid.

On December 18, 1964, Spouses Salvador executed a deed of reconveyance in favor of Celestinos estate. Branch I
ordered a new deed of reconveyance in favor of the 31 persons substituted as plaintiff in that action and accordingly,
a new deed was made.

Following this, Branch I ordered the TCT in the name of the administrator canceled, new TCT to be issued in the
name of the 21 persons.

On December 2, 1965, Branch I ordered PNB to release the proceeds of the sale of Lot 6 to the 21 plaintiffs,
apparently, although the passbook was given by the administrator to the 21 persons, no release was made as PNB
awaited Branch IIs order.

Branch II approved the claims against the estate and release the amount to the administrator to pay the debts of the
estate.

Soon after, the 21 persons filed the present special civil action for certiorari with preliminary injunction questioning
Branch IIs power to dispose land involved in a recnveyance suit in Branch I.

Issue: Whether or not parcels of land of the proceeds are properties of the estate.

Ruling: Yes, the parcels of lands belong to the estate of the deceased Celestino Salvador. Notwithstanding the
transmission of hereditary rights upon the death of the decedent the right of the heirs to specific distributive shares
of the inheritance does not become finally determinable until all the debts of the estate are paid. Until then, in the
face of said claims, their rights cannot be enforced, are inchoate, and subject to the existence of a residue after
payment of the debts.