Corpus v.

CA

116

G.R. No. L-22469, October 23, 1978, Aquino, J.

Digested by Pat Law 105- Succession
Topic: Order of Intestate Succession
Decedent Teodoro is an acknowledged natural child of his father. When he died, he left a will and no forced heirs.
The will was contested by the PET Corpus, the grandson of decedents half brother who is a legitimate child. He
argued that since the will is invalid, the rules on intestacy should apply. Hence, he can recover his mothers
supposed share in the intestate estate of deceased. The SC held that the PET Corpus has no cause of action to
recover the supposed intestate share of his mother in the estate of deceased holding that there is no reciprocal
succession between legitimate and illegitimate relatives.

FACTS
Teodoro Yangco is the son of Luis Yangco Sr. and Ramona Arguelles.
o Note: Teodoro and the other children of Luis Sr. were acknowledged natural and not
legitimate children as admitted by the latter in his will.
Before union with Luis Sr., Ramona had already begotten five children with former husband
Tomas Corpus including Pablo and Jose Corpus.
Teodoro Yangco died. His will was probated by the CFI and affirmed by the SC.
At the time of his death, he had no forced heirs. His nearest relatives were:
o
o
o

Brother Luis
Sister Paz
Children of half brother Pablo

o Juanita Corpus, daughter of half brother Jose

There was a controversy regarding the project of partition of Teodoros estate submitted by the
administrator. But eventually this was solved when the legatees and the other heirs entered into
compromise agreements.
Subsequently, PET Tomas Corpus, the sole heir of Juanita, filed an action in the CFI to recover
her supposed share in the Yangcos intestate estate.
o He alleged that the dispositions in Yangcos will imposing perpetual prohibition upon
alienation rendered it void under the Old Civil Code and the partition is invalid, and
therefore, the estate should be distributed according to the rules of intestacy.
TC dismissed the action on the grounds of res judicata and laches.

ISSUES & HOLDING

Whether PET Tomas Corpus has a cause of action to recover his mothers supposed intestate share in
Yangcos estate- NO. His mother Juanita is not a legal heir of Teodoro Yangco.
RATIO
First: Teodoro Yangcos filiation
Teodoro was an acknowledged natural child and not a legitimate of Luis Sr.

o This was admitted by Luis Sr. in his will which was duly probated.
o The authenticity of that will is incontestable. It is part of a public or official judicial
record.
On the other hand, the children of Ramona Arguelles and Tomas Corpus Sr. (including the father
of PETs mother Juanita) are presumed to be legitimate.
o A marriage is presumed to have taken place between Ramona and Tomas Sr.

There is no reciprocal succession between legitimate
and illegitimate relatives
Art. 943 of the Old Civil Code prohibited all successor reciprocity mortis causa between
legitimate and illegitimate relatives.
The same rule is now found in Art. 992, NCC: 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.
o The rule is based on theory that the illegitimate child is disgracefully looked upon by the
legitimate family while the legitimate family is, in turn, hated by the illegitimate child.
The law does not recognize the blood tie and seeks to avoid further grounds of
resentment. (Manresa)
Hence, Teodoro Yangcos half brothers on the Corpus side, who were legitimate, had no
right to succeed his estate under the rules of intestacy.
o It is clear that Juanita Corpus was not a legal heir of Yangco. Therefore, PET Tomas
Corpus has no cause of action for the recovery of the supposed hereditary share of his
mother in Yangcos estate.
SC, following this rule, has previously held that:
o Legitimate relatives of the mother cannot succeed her illegitimate child (Cacho v. Udan)
o Natural child cannot represent his natural father in the succession to the estate of the
legitimate grandparent (Llorente v. Rodriguez)
o Natural daughter cannot succeed to the estate of her deceased uncle, a legitimate brother
of her natural mother. (Anuran v. Aquino)
DISPOSITIVE
Affirmed. Petition denied.