Spouses Isidro R. Salitico v. Heirs of Resurreccion Martinez Felix

Summary

This case involves a property dispute arising from inheritance and subsequent sale. Amanda H. Burgos devised her land to niece Resurreccion Martinez Felix through a will. Resurreccion sold the property to Spouses Salitico, who took possession but could not obtain title transfer due to pending estate settlement. When heirs demanded return of the property, Spouses Salitico filed for specific performance. The Supreme Court partially granted relief, ruling that while heirs can validly sell inherited property immediately upon death (Article 777, Civil Code), actual title transfer requires court approval under property registration laws (PD 1529). The Court ordered delivery of the owner's duplicate certificate but denied title cancellation pending final estate distribution. This decision clarifies the distinction between inheritance rights transmission and formal property registration requirements.