Friday, November 7, 2014

Corpuz v. Administrator




·          Teodoro R. Yangco died in Manila at the age of seventy-seven years. His will was probated in the CFI.
·          Yangco had no forced heirs. At the time of his death, his nearest relatives were
o    (1) his half brother, Luis R. Yangco,
o    (2) his half sister, Paz Yangco,
o    (3) Amalia Corpus, Jose A. V. Corpus, and Ramon L. Corpus, the children of his half brother, Pablo Corpus, and
o    (4) Juana (Juanita) Corpus, the daughter of his half brother Jose Corpus. (†)
·          A project of partition was submitted by the administrator and the legatees named in the will. That project of partition was opposed by the estate of Luis R. Yangco whose counsel contended that an intestacy should be declared because the will does not contain an institution of heir.
·          The Probate court approved the project of partition. Appeals were taken by Pedro Martinez, Juliana de Castro , Juanita Corpus (deceased) and the estate of Luis R. Yangcobut were dismissed after the legatees and the appellants entered into compromise agreements.
·          In the compromise the legatees agreed to pay P35,000 to Pedro Martinez, the heirs of Pio V. Corpus, peaches, the heirs of Isabel Corpus and the heir of Juanita Corpus (Tomas Corpus). Tomas Corpus signed that compromise settlement and received from the Yangco estate P2,000as settlement of his full share. 
·          But, subsequently, Tomas Corpusfiled an action to recover her (Juanita’s) supposed share in Yangco intestate estate.
·          He alleged in his complaint that the dispositions are void since it was a perpetual prohibition on alienation and an intestacy be declared.
·          TC dismissed the action on the grounds of res judicata and laches.
·          CA endorsed the case to the SC since it covers real property valued at more than 50k.

Issue: WON Tomas Corpus may inherit from TeodoroYangco [NO, because his mother (Juana Corpus does not have the right to inherit via intestacy from his half-blood brother]

Ruling:
·          Trial Court: Teodoro R. Yangco was an acknowledged natural child and not a legitimate child. Itwas proven in the statement in the will of his father, Luis Rafael Yangco.
·          Court presumed that there was a marriage between Ramona and Tomas (first family).
·          Since Teodoro R. Yangco was an acknowledged natural child or was illegitimate and since Juanita Corpus was the legitimate child of Jose Corpus, himself a legitimate child, we hold that appellant Tomas Corpus has no cause of action for the recovery of the supposed hereditary share of his mother, Juanita Corpus, as a legal heir, in Yangco's estate. Juanita Corpus was not a legal heir of Yangco because there is no reciprocal succession between legitimate and illegitimate relatives.
·          OCC 943 "prohibits all successory reciprocity mortis causa between legitimate and illegitimate relatives"
·          article 992 of the Civil Code which provides that "an illegitimate child has no right to inherit ab intestato from the legitimate children and relatives of his father or mother; nor shall such children or relatives inherit in the same manner from the illegitimate child".
·          Under articles 944 and 945 of the Spanish Civil Code, "if an acknowledged natural or legitimated child should die without issue, either legitimate or acknowledged, the father or mother who acknowledged such child shall succeed to its entire estate; and if both acknowledged it and are alive, they shall inherit from it share and share alike. In default of natural ascendants, natural and legitimated children shall be succeeded by their natural brothers and sisters in accordance with the rules established for legitimate brothers and sisters."
·          Hence, Teodoro R. Yangco'shalf brothers on the Corpus side, who were legitimate, had no right to succeed to his estate under the rules of intestacy.
·          By reason of that same rule, the natural child cannot represent his natural father in the succession to the estate of the legitimate grandparent. The natural daughter cannot succeed to the estate of her deceased uncle, a legitimate brother of her natural mother

·          Trial Court Affirmed.

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