Ricardo Distajo v. Court of Appeals

Summary

This case involves a family dispute over inherited land parcels originally owned by Iluminada Abiertas in Capiz. Her heirs challenged the validity of sales made by Iluminada to her son Rufo Distajo, who served as administrator of the properties, claiming the transactions violated Civil Code prohibitions against administrators purchasing property under their management. The trial court dismissed the complaint, but the Court of Appeals partially granted it, ordering partition of one lot. The Supreme Court affirmed the appellate court's decision, ruling that the sales were valid under Article 1491(2) of the Civil Code because the principal (Iluminada) consented to the sales. The Court rejected claims of forgery for lack of convincing evidence and held that the principal's consent removes such transactions from the prohibition against administrators acquiring property under administration. The case establishes that administrator-principal sales are permissible with proper consent.