ALVAREZ vs IAC

Two parcels of land were registered in the names of Ancieto Yanes, father of herein respondents alright?
Were talking about an Original Certificate of Title alright (OCT)? Now for some reason a certain
Fortunato Santiago was issued a Transfer Certificate of Tittle (TCT), meaning there was a transfer of
ownership, in what mode? most probably a sale. Santiago then sold the lots to Monico Fuentebella.
Then the lots were sold thereafter to Rosendo Alvarez. So three TCTs in one sitting everyone
seemed to be itching to quickly dispose it, the first transfer of ownership must be a falsificated sale.
So person A is the original owner, person B got a hold of the title to his property, sold it to person C,
who in turn sold it to person D. Oh but wait there's more. There's a person E. And he's coming, wait for
it.

So the Yaneses filed a complaint against the three. Santiago, Fuentebella and Alvarez and wait.. there's
one more, the 4th person imputed in his filed case, only its not a person perse, its a juridical person.
The Register of Deeds of Negros Occidental, which must have been the source of all the falsification.
Yanes petitioned the return and owndership of the lots and prayed for an accounting of the produce of
the land from 1944 up to the filing of the complaint with damages.

Enter person E. Take note. Now during the pendency of the case, Alvarez offered the lots to Dr.
Rodolfo Siason. Now Dr. Siason unsuspecting and unaware of the previous dubitable contracts and the
pending case bought the lots.

Comes out the decision, The CFI (Court of First Instance) (This is an old case that's how they call their
RTC then.) ordered Alvarez to reconvey and deliver the possession of the lots to Yanes. Here comes
the controversy. The court order proved to be inexecutable with respect to the one lot since it had been
subdivided into two, and they were in the name of the doctor who purchased them in good faith from
Alvarez, and that the lot could not be delivered back to the plaintiff since Dr. Siason was not a party in
the writ of execution.

So the Yaneses filed a petition for the issuance of a new certificate of title and for the declaration of
nullity of the TCTs issued to Alvarez. But the lower court found Siason as a buyer in good faith. Tsk
tsk.. it could have stopped in Alvarez you know, the reconveyance would not have seemed to be a
problem you know, but the court saw a 3rd party liability in here in the person of Siason, and the court
just had to protect that, gets?

Meanwhile in the middle of all these Rosendo Alvarez died. He probably couldn't take it anymore.
Hahaha.. don't quote me on that. And so the court ordered the heirs of Alvarez to pay the Yaneses the
actual value of the lots, plus damages. The IAC, meaning Intermediate Appellate Court (Their CA
during their time) affirmed the CFI decision except with regard to the damages. Heirs of Alvarez
contends the liability arising from the sale of the lots made by their father to Dr. Siason should be the
sole liability of the late Rosendo Alvarez or of his estate after his death.

ISSUE:
WON the Heirs of Alvarez' contention that the liability arising from the sale of the lots made to Dr.
Siason should be the sole liability of the late Rosendo Alvarez or of his estate after his death.

RULING:

NO. - Under our law, the general rule is that a party's contractual rights and obligations are
transmissible to the successors. The pertinent provisions of the Civil Code state:

Art. 774.

Succession is a mode of acquisition by virtue of which the property, rights and obligations to the extent
of the value of the inheritance, of a person are transmitted through his death to another or others either
by his will or by operation of law.

Art. 776.

The inheritance includes all the property, rights and obligations of a person which are not extinguished
by his death.

Art. 1311

Contracts take effect only between the parties, their assigns and heirs except in case where the rights
and obligations arising from the contract are not transmissible by their nature, or by stipulation or by
provision of law. The heir is not liable beyond the value of the property received from the decedent.

In the Estate of Hemady vs. Luzon Surety Case, the court ruled that:

The binding effect of contracts upon the heirs of the deceased party is not altered by the provision of
our Rules of Court that money debts of a deceased must be liquidated and paid from his estate before
the residue is distributed among said heirs (Rule 89). The reason is that whatever payment made from
the state is ultimately a payment by the heirs, since the amount of the paid claim in fact diminishes or
reduces the shares that the heirs would have been entitled to receive.

Petitioners being the heirs of the late Rosendo Alvarez, they cannot escape the legal consequences of
their father's transaction, which gave rise to the present claim for damages.

That petitioners did not inherit the property involved is of no moment because by legal fiction, the
monetary equivalent thereof devolved into the mass of their father's hereditary estate, and hereditary
assets are always liable in their totality for the payment of the debts of the estate.

It must, however, be made clear that petitioners are liable only to the extent of the value of their
inheritance.

Heirs of Alvarez loses this case

Bienvenido Gevero v. Intermediate Appellate Court and Del Monte Development Corporation
(DELCOR) G.R. No. 77029; August 30, 1990

Facts: DELCOR purchased a lot (lot 2476-A; 20,119 sq met) from the late Luis Lancero. As per Deed
of Absolute Sale exec in favor of DELCOR, a TCT was issued. Luis acquired the same parcel of land
from Ricardo Gevero(1952). The sale bet Luis and Ricardo waqs annotated at the back of an OCT
covering a mother lot(lot no. 2476) in the names of Ricardo, his mother Teodorica and his siblings.
Teodorica died long before WW2. In 1966, an extra-judicial settlement and partition was executed by
the heirs of Teo. Lot 2476 was adjudicated in favor of Ricardo who was then alive. DELCOR filed an
action with the CFI of Misamis Oriental to quiet title and/or annul the partition made by the heirs
insofar as the same prejudices the land which it acquired. After trial court rendered judgment in favor
of plaintiff corporation. The appellate court affirmed the decision. Wills

Issue: WON the 1/2 share of interest of Teodorica in one of the litigated lots is included in the deed of
sale.

Ruling: Yes. The hereditary share in a decedents' estate is transmitted or vested immediately from the
moment of the death of the "causante" or predecessor in interest (Art. 777), and there is no legal bar to
a successor disposing of his hereditary share immediately after such death, even if the actual extent of
such share is not determined until the subsequent liquidation of the estate. Teodorica Babangha died
long before World War II, hence, the rights to the succession were transmitted from the moment of her
death. It is therefore incorrect to state that it was only in 1966, the date of extrajudicial partition, when
Ricardo received his share in the lot as inheritance from his mother Teodorica. Thus, when Ricardo
sold his share over lot 2476 that share which he inherited from Teodorica was also included unless
expressly excluded in the deed of sale.

Mariano B. Locsin v. Court of Appeals G.R. No. 89783; February 19, 1992

Facts: Mariano inherited extensive property from his father Getulio. He brought his inheritance into his
marriage with Catalina Jaucian. Catalina, for her part, brought into the marriage untitled properties
which she had inherited form her parents. Mariano Locsin executed a last will and testament instituting
his wife as the sole and universal heir of all his properties. The spouses being childless, they had agreed
that their properties, after both of them shall have died should revert to their respective sides of the
family. After Mariano's death, (1948) his will was probated without opposition from both sides of the
family. Nine years after the death of Don Mariano, Catalina began transferring, by sale, donation or
assignment, Mariano's as well as her own, props to their respective nephews and nieces. Catalina died
in 1977. Four years before her death, she made a will affirming the transfers she made. Six years after
her demise, some of Catalina's nephews and nieces filed an action in the RTC of Legaspi to recover the
properties which she had conveyed to the Locsins, alleging that the conveyances were innoficious,
without consideration, and intended solely to circumvent the laws on succession. After the trial,
judgment was rendered in favor of the plaintiffs. The Court of Appeals affirmed the trial court's
decision.

Issue: WON the PRs are entitled to inherit the properties which Catalina had already disposed of more
than 10 yrs before her death.
 Ruling: No. The properties did not form part of her hereditaty estate. The rights to a person's
succession are transmitted from the moment of his death, and do not vest in his heirs until such time. 11
Property which Doña Catalina had transferred or conveyed to other persons during her lifetime no
longer formed part of her estate at the time of her death to which her heirs may lay claim. Had she died
intestate, only the property that remained in her estate at the time of her death devolved to her legal
heirs; and even if those transfers were, one and all, treated as donations, the right arising under certain
circumstances to impugn and compel the reduction or revocation of a decedent's gifts inter vivos does
not inure to the respondents since neither they nor the donees are compulsory (or forced) heirs. There is
thus no basis for assuming an intention on the part of Doña Catalina, in transferring the properties she
had received from her late husband to his nephews and nieces, an intent to circumvent the law in
violation of the private respondents' rights to her succession. Said respondents are not her compulsory
heirs, and it is not pretended that she had any such, hence there were no legitimes that could
conceivably be impaired by any transfer of her property during her lifetime. All that the respondents
had was an expectancy that in nowise restricted her freedom to dispose of even her entire estate subject
only to the limitation set forth in Art. 750, Civil Code which, even if it were breached, the respondents
may not invoke.

Natalia Opulencia v. Court of Appeals, Aladin Simundac and Miguel Olivan G.R. Mo. 125835;
July 30, 1998

Facts: PRs Aladin Simundac and Miguel Oliven filed a complaint for specific performance again
Natalia Carpena Opulencia on the ground that the latter executed in their favor a 'contract to sell' of lot
2125. The defendant, despite demands, failed to comply with her obligations under the contract. The
defendant averred that the property subject of the contract formed part of the Estate of Demetrio
Carpena, in respect of which a petition for probate was filed with the RTC of Binan. The court ordered
the parties to submit their evidence. Pet, instead of submitting evid, filed a demurrer. Moreover, the pet
maintained that the contract was null and void for want of approval of the probate court. Meanwhile,
the court a quo granted the demurrer and dismissed the complaint. On appeal, the appellate court set
aside hte trial court's dismissal of the complaint.

Issue: WON a contract to sell a real property involved in estate proceedings valid and binding without
the approval of the probate court.

Ruling: Yes. Hereditary rights are vested in the heir or heirs from the moment of the decedent's death.
Petitioner, therefore, became the owner of her hereditary share the moment her father died. Thus, the
lack of judicial approval does not invalidate the Contract to Sell, because the petitioner has the
substantive right to sell the whole or a part of her share in the estate of her late father. Petitioner
contends that "[t]o sanction the sale at this stage would bring about a partial distribution of the
decedent's estate pending the final termination of the testate proceedings." Petitioner's contention is not
convincing. The Contract to Sell stipulates that petitioner's offer to sell is contingent on the "complete
clearance of the court on the Last Will Testament of her father." Consequently, although the Contract
to Sell was perfected between the petitioner and private respondents during the pendency of the probate
proceedings, the consummation of the sale or the transfer of ownership over the parcel of land to the
private respondents is subject to the full payment of the purchase price and to the termination and
outcome of the testate proceedings. Therefore, there is no basis for petitioner's apprehension that the
Contract to Sell may result in a premature partition and distribution of the properties of the estate.
Indeed, it is settled that "the sale made by an heir of his share in an inheritance, subject to the pending
administration, in no wise stands in the way of such administration."
Emilio Emnace v. Court of Appeals and the Estate of Vicente Tabanao (plus heirs) G.R. No.
126334; November 23, 2001

Facts: Pets Emnace, Tabanao and Divigranacia were partners in a business known as Ma. Nelma
Fishing Industry. Sometime in January 1986, they decided to dissolve their partnership and exec an
agreement of partition and distribution. Throughout the existence of the partnership, and even after
Tabanao's death, pet failed to submit to Taba's heirs any financial statements. Pet also reneged on his
promise to turn over the 1/3 share in the total assets of the partnership to the heirs. PRs(heris) filed an
action for accounting, payment of shares, division of assets and damages. Pet filed a motion to dismiss
the complaint on the grounds of improp venue, lack of juris and lack of capacity of the estate of Tabano
to sue. The trial court denied the motion to dismiss. The trial court held that the heirs of Tabano had a
right to sue in their own names, in view of the provision of Art. 777 of the CC.

Issue: Legal capacity of the surviving spouse of Tabano to sue.

Ruling: Yes. petitioner asserts that the surviving spouse of Vicente Tabanao has no legal capacity to
sue since she was never appointed as administratrix or executrix of his estate. Petitioner’s objection in
this regard is misplaced. The surviving spouse does not need to be appointed as executrix or
administratrix of the estate before she can file the action. She and her children are complainants in their
own right as successors of Vicente Tabanao. From the very moment of Vicente Tabanao's death, his
rights insofar as the partnership was concerned were transmitted to his heirs, for rights to the
succession are transmitted from the moment of death of the decedent. Whatever claims and rights
Vicente Tabanao had against the partnership and petitioner were transmitted to respondents by
operation of law, more particularly by succession, which is a mode of acquisition by virtue of which
the property, rights and obligations to the extent of the value of the inheritance of a person are
transmitted. Moreover, respondents became owners of their respective hereditary shares from the
moment Vicente Tabanao died. A prior settlement of the estate, or even the appointment of Salvacion
Tabanao as executrix or administratrix, is not necessary for any of the heirs to acquire legal capacity to
sue. As successors who stepped into the shoes of their decedent upon his death, they can commence
any action originally pertaining to the decedent. From the moment of his death, his rights as a partner
and to demand fulfillment of petitioner's obligations as outlined in their dissolution agreement were
transmitted to respondents. They, therefore, had the capacity to sue and seek the court's intervention to
compel petitioner to fulfill his obligations.

Johny Rabadilla v. Court of Appeals G.R. No, 113725; June 29, 2000

Facts: Testator Aleja Belleza appended a codicil to his last will and testament wherein he instituted Dr.
Jorge Rabadilla as a devisee of 511, 855 sq meters of a parcel of land in Bacolod. Devisee herein is the
predecessor-in-interest of the petitioner. The codicil was duly probated and admitted before the CFI of
Negros Occidental. The codicil stated that should the devisee die ahead of the testator, the property and
rights shall be inherited by his children and spouse. The codicil also required Rabadilla to deliver 75
piculs of export sugar and 25 piculs of domestic sugar to Maria Marlina Cosculuella y Belleza, and
should he die, his heir shall have the same obligation. Lastly, in the event that the devisee or his heir
shall later sell, lease, mortgage the said lot, the buyer, lessee, mortgagee shall also have the obligation
to deliver the piculs. Dr. Rabadilla died in 1983 and was survived by his wife and children (pet). In
1989, Maria Marlena brought a complaint against the heirs to enforce the provisions of the codicil and
to revert the ownership to the heirs of the testator. The RTC dismissed the complaint. The appellate
court reversed the decision of the trial court..

Ruling: Yes. Petitioner maintains that Article 882 does not find application as there was no modal
institution and the testatrix intended a mere simple substitution. Under Article 776 of the New Civil
Code, inheritance includes all the property, rights and obligations of a person, not extinguished by his
death. Conformably, whatever rights Dr. Jorge Rabadilla had by virtue of subject Codicil 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 Codicil on the
deceased Dr. Jorge Rabadilla, were likewise transmitted to his compulsory heirs upon his death. In the
said Codicil, testatrix Aleja Belleza devised Lot No. 1392 to Dr. Jorge Rabadilla, subject to the
condition that the usufruct thereof would be delivered to the herein private respondent every year.
Upon the death of Dr. Jorge Rabadilla, his compulsory heirs succeeded to his rights and title over the
said property, and they also assumed his (decedent's) obligation to deliver the fruits of the lot involved
to herein private respondent. Such obligation of the instituted heir reciprocally corresponds to the right
of private respondent over the usufruct, the fulfillment or performance of which is now being
demanded by the latter through the institution of the case at bar. Therefore, private respondent has a
cause of action against petitioner and the trial court erred in dismissing the complaint below.

Modal Institutions::*Petitioner also theorizes that Article 882 of the New Civil Code on modal
institutions is not applicable because what the testatrix intended was a substitution - the contention is
without merit. In simple substitutions, the second heir takes the inheritance in default of the first heir by
reason of incapacity, predecease or renunciation. [14] In the case under consideration, the provisions of
subject Codicil do not provide that should Dr. Jorge Rabadilla default due to predecease, incapacity or
renunciation, the testatrix's near descendants would substitute him. What the Codicil provides is that,
should Dr. Jorge Rabadilla or his heirs not fulfill the conditions imposed in the Codicil, the property
referred to shall be seized and turned over to the testatrix's near descendants.

Belinda Taredo v. Court of Appeals G.R. No. 104482; January 22, 1996

Facts: On October 20, 1962, Lazardo Tanedo executed a notarized deed of absolute sale of one
hectare of whatever share I shall have over Lot No. 191" in favor of his eldest brother and his wife
(Ricardo and Teresita PRs). Upon hte death of his father, Lazaro executed an "Affidavit of
Conformity" to reaffirm, respect and acknowledge the sale in favor or PRs. Lazaro executed another
notarized deed of sale on favor of PRs covering 1/12 of a Lot 191. Ricardo learned taht Lazaro sold the
same lot to his children. PRs recorded the deed in the RD. Pets filed a complaint for rescission
executed by Lazaro in favor of the PRs. The trial court decided in favor of PRs. The CA affirmed the
decision of the trial court.

Issue: WON the sale of future inheritance is valid.

Ruling: Yes! Read Art. 1347.. A second deed of sale was executed in favor of private respondents
covering Lazaro's undivided inheritance dated 1982, so nevermind the previous deed ya know. The
deed of sale in favor of respondents was executed in 1980. However, according to Art. 1544 of the CC:
Art. 1544. If the same thing should have been sold to different vendees, the ownership shall be
transferred to the person who may have first taken possession thereof in good faith, if it should be
movable property. Should it be immovable property, the ownership shall belong to the person acquiring
it who in good faith first recorded it in the Registry of Property. The property in question is land, an
immovable, and following the above-quoted law, ownership shall belong to the buyer who in good
faith registers it first in the registry of property. Thus, although the deed of sale in favor of private
respondents was later than the one in favor of petitioners, ownership would vest in the former because
of the undisputed fact of registration. On the other hand, petitioners have not registered the sale to them
at all.

Sps Virgilio Santos and Esperanza Lati Santos v. Sps. Jose Lumbao and Proserfina Lumbao;
G.R. No. 169129; March 28, 2007

Facts: Herein pets are the legitimate and surviving heirs of the late Rita Catoc Santos, who died on
October 20, 195. The other pets are the daughters-in-law of Rita. The respondents are the alleged
owners of a lot, which they purportedly bought from on two occasions. On the first occasion, Rita sold
100 square meters of her inchoate share in her mother’s estate through a document denominated as
"Bilihan ng Lupa,― Before her death, Rita allegedly informed the respondents that she could not
deliver the title to the subject prop because the entire property inherited by her had not yet been
partitioned. The PRs claimed that pets adjudicated and partitioned the subject property already sold to
them. They filed a formal demand letter but pets still failed and refused to reconvey the subject
property. The trial court denied the complaint. The CA reversed the decision. MR denied.

Issue: WON herein pets are legally bound to comply with the "Bilihan ng Lupa" and consequently,
reconvey the subject property to herein respondents.

Ruling: The general rule that heirs are bound by contracts entered into by their predecessors-ininterest
applies in the present case. Article 131132 of the NCC is the basis of this rule. It is clear from the said
provision that whatever rights and obligations the decedent have over the property were transmitted to
the heirs by way of succession, a mode of acquiring the property, rights and obligations of the decedent
to the extent of the value of the inheritance of the heirs. Thus, the heirs cannot escape the legal
consequence of a transaction entered into by their predecessor-in-interest because they have inherited
the property subject to the liability affecting their common ancestor. Being heirs, there is privity of
interest between them and their deceased mother. They only succeed to what rights their mother had
and what is valid and binding against her is also valid and binding as against them. The death of a party
does not excuse nonperformance of a contract which involves a property right and the rights and
obligations thereunder pass to the personal representatives of the deceased. Similarly, nonperformance
is not excused by the death of the party when the other party has a property interest in the subject
matter of the contract. In the end, despite the death of the petitioners’ mother, they are still bound
to comply with the provisions of the "Bilihan ng Lupa,".

NHA v. Segunda Almeida, CA G.R. No. 162784; June 22, 2007

Facts: The Land Tenure Administration awarded to Margarita Herrera several portions of land in San
Pedro, Laguna. She had two children, Francisca and Beatriz(she died before her mom; mother of PR).
When Margarita passed away, Francisca executed a deed of selfadjudication claiming that she was the
only remaining relative of Margarita. The deed of was based on a 'Sinumpaang Salaysay' allegedly
executed by Margarita. The surviving heirs of Beatriz filed a case for annulment of the deed. A
decision was rendered and the deed was declared null and void. During the trial, Francisca filed an
application with the NHA to purchase the same lots. The NHA granted the application. The PR
appealed to the Office of the President. The NHA reso was affirmed. When Francisca died, her heirs
executed an extrajudicial settlement of her estate which they submitted to the NHA. The transfer of
rights was approved by the NHA. The heirs of Francisca directed PR to leave the premises that she was
occupying. Feeling aggrieved, PR sought the cancellation of the titles issued in favor of the heirs of
Francisca. She filed a complaint in the RTC of San Pedro, Laguna. She invoked her 40 year occupation
of the property and re-raised the fact that Francisca's declaration is a nullity because the other heirs
were disregarded. The RTC dismissed the case for lack of jurisdiction. The CA reversed the decision
and remanded the case for further hearing. The RTC rendered a decision setting aside the resolution of
the NHA and the decision of the Office of the President. The Regional Trial Court ruled that the
"Sinumpaang Salaysay" was not an assignment of rights but a disposition of property which shall take
effect upon death. It then held that the said document must first be submitted to probate before it can
transfer property. The NHA and the heirs of Francisca filed their respective motions which were both
denied. The CA affirmed the decision of the trial court.

Issue: WON the decision of NHA is arbitrary.

Ruling: Yes. The NHA gave due course to the application made by Francisca Herrera without
considering that the initial applicant's death would transfer all her property, rights and obligations to the
estate including whatever interest she has or may have had over the disputed properties. To the extent
of the interest that the original owner had over the property, the same should go to her estate. Margarita
Herrera had an interest in the property and that interest should go to her estate upon her demise so as to
be able to properly distribute them later to her heirs in accordance with a will or by operation of law.
When the original buyer died, the NHA should have considered the estate of the decedent as the next
"person" likely to stand in to fulfill the obligation to pay the rest of the purchase price. The opposition
of other heirs to the repurchase by Francisca Herrera should have put the NHA on guard as to the
award of the lots. Further, the Decision in the said Civil Case No. B-1263 (questioning the Deed of
Self-Adjudication) which rendered the deed therein null and void should have alerted the NHA that
there are other heirs to the interests and properties of the decedent who may claim the property after a
testate or intestate proceeding is concluded. The NHA therefore acted arbitrarily in the award of the
lots.

G.R. No. 84450 February 4, 1991

PEOPLE OF THE PHILIPPINES, plaintiff-appellee, 
vs.
GLORIA UMALI y AMADO AND

SUZETH UMALI y AMADO, defendants-appellants.

FACTS:

Francisco Manalo, was investigated by operatives of the Tiaong, Quezon Police Department and for
which a case for violation of the Dangerous Drug Act was filed against him. He was likewise facing
other charges such as concealment of deadly weapon and other crimes against property. Pat. Felino
Noguerra went to the Tiaong Municipal Jail, and sought the help of Francisco to identify the source of
the marijuana. In return he asked the policeman to help him in some cases pending against him. He did
not negotiate his case for violating the dangerous drug act, as he has entered a plea of guilty.

Pfc. Sarmiento, Chief of the Investigation Division gave Manalo four (4) marked P5.00 bills to buy
marijuana from sources known to him. Few minutes there after, Manalo returned with two (2) foils of
dried marijuana which were allegedly bought from the accused Gloria Umali. Thereafter, he was asked
by the police investigators to give a statement on the manner and circumstances of how he was able to
purchase marijuana foils from accused Gloria Umali. After securing a search warrant, with the help of
Manalo’s affidavit, supported by the toils of marijuana, the police operatives, went to the house of
Gloria Umali, in the presence of Brgy. Capt. Punzalan, served the search warrant and were able to
confiscate from the person of Gloria Umali the four P5.00 bills with serial numbers as reflected in the
police blotter and a can of milo, containing sixteen (16) foils of dried marijuana leaves.

Gloria Umali and Suzeth Umali were charged for violation of Dangerous Drugs Act of 1972. Upon
arraignment, Gloria Umali entered a plea of "not, guilty" as accused Suzeth Umali remained at large.
After trial, the lower court rendered a decision finding accused Gloria Umali guilty beyond reasonable
doubt and sentenced to suffer the penalty of Reclusion Perpetua.

ISSUE: Whether or not Manalo’s testimony should be given credit

HELD: The appellant vehemently denied the findings of the lower court and insisted that said court
committed reversible errors in convicting her. She alleged that witness Francisco Manalo is not reputed
to be trustworthy and reliable and that his words should not be taken on its face value. Furthermore, he
stressed that said witness has several charges in court and because of his desire to have some of his
cases dismissed, he was likely to tell falsehood.

Rule 130, Section 20 of the Revised Rules of Court provides that: “Except as provided in the next
succeeding section, all persons who can perceive, and perceiving can make known their perception to
others may be witnesses. Religious or political belief, interest in the outcome of the case, or conviction
of a crime unless otherwise provided by law, shall not be a ground for disqualification.” The phrase
"conviction of a crime unless otherwise provided by law" takes into account Article 821 of the Civil
Code which states that persons convicted of falsification of a document, perjury or false testimony" are
disqualified from being witnesses to a will." Since the witness Francisco Manalo is not convicted of
any of the above-mentioned crimes to disqualify him as a witness and this case does not involve the
probate of a will, We rule that the fact that said witness is facing several criminal charges when he
testified did not in any way disqualify him as a witness. The testimony of a witness should be given full
faith and credit, in the absence of evidence that he was actuated by improper motive. Hence, in the
absence of any evidence that witness Francisco Manalo was actuated by improper motive, his
testimony must be accorded full credence.