Heirs of Arturo Reyes v. Elena Socco-Beltran

Summary

This case involves a property ownership dispute over Lot No. 6-B in Bataan between heirs of Arturo Reyes who claimed ownership through a 1954 Contract to Sell, and Elena Socco-Beltran who claimed ownership through extrajudicial settlement of her predecessor's estate. The Supreme Court ruled in favor of respondent, finding the Contract to Sell invalid under Article 1459 of the Civil Code because the vendor Miguel Socco did not own the property at the time of sale, being merely an expectant heir. Petitioners also failed to prove conclusive possession for acquisitive prescription despite claiming occupation since 1954. Respondent's claim was stronger as she inherited from the original allocatees who had fully paid for the property. However, the Court withheld confirmation of the CLOA issued to respondent's representative pending proper determination of respondent's legal heirs, as respondent had died during proceedings and her right of succession was unclear.