G.R. No. 120344 - Paddayuman vs. People

Codicil, probate, and administration
On September 29, 1944, Benigno Diaz executed a codicil to his will containing, among others, clause 9 (excluding spouses from legacies) and clause 10, which provided that after 10–15 years all properties could be sold, with ₱1,000 reserved for four nephews and sums for masses, and that the residue “se distribuirá a las siguientes personas que aún viven, o a sus descendientes legítimos,” naming four persons with percentage shares.
Benigno Diaz died on November 7, 1944; his will and codicil were probated in Special Proceedings No. 894, CFI Manila. The estate administration closed in 1950, and the Bank of the Philippine Islands was appointed trustee for the legatees.

Death of Filomena Diaz and petitioner’s claim
Filomena Diaz, one of the residuary legatees under clause 10, died on February 8, 1954, leaving two legitimate daughters: Milagros Belen de Olaguera (married, with seven legitimate children) and Onesima D. Belen (single).
On March 19, 1958, Onesima filed a petition in Special Proceedings No. 9226, claiming that Filomena’s share should be divided equally between her and Milagros, to the exclusion of Milagros’s seven children.
By order dated May 23, 1958, the CFI denied the petition, relying on its September 28, 1959 resolution that Filomena’s share “pertains to her legitimate descendants” and must be distributed among all descendants (children and grandchildren).

Prior decision’s effect
Whether the Supreme Court’s decision in Arguelles v. Belen de Olaguera (G.R. No. L-10164, Feb. 28, 1958) affirmed the trial court’s interpretation of clause 10.
Construction of “sus descendientes legítimos”
Whether the phrase refers to all living descendants of the legatee (children and grandchildren) or only those nearest in degree (the legatee’s children).