Prisca Naval v. Francisco Enriquez

Summary

Heirs challenged two sequential sales of hereditary rights in estates, claiming lack of consideration and executor's legal incapacity to acquire such rights. The Supreme Court upheld the validity of both sales, finding sufficient evidence of consideration based on notarial presumptions and witness testimony. The Court ruled that even if consideration was lacking, the action was time-barred under the four-year prescription period for nullity actions. Significantly, the Court held that Article 1459's prohibition on executors purchasing estate property does not extend to hereditary rights, which belong entirely to heirs and can be disposed of independently of estate administration. The decision establishes important precedents regarding the scope of executor limitations and the evidenciary weight of notarial documents in contract disputes.