Case Digest (G.R. No. L-14070) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. L-14070, decided March 29, 1961, plaintiffs-appellants Maria Gervacio Blas, Manuel Gervacio Blas, Leoncio Gervacio Blas, and Loida Gervacio Blas sued Rosalina Santos, special administratrix of the estate of the deceased Maxima Santos de Blas, before the Court of First Instance of Rizal (Sp. Proc. No. 2524). They alleged that on December 26, 1936, Maxima Santos executed a written promise (Exhibit A) to deliver upon her death one-half of the conjugal properties she would acquire by law as widow of Simeon Blas—properties that he and his first wife, Marta Cruz, had amassed but never liquidated. These conjugal properties had been included and partitioned in the estate settlement of Simeon Blas in Civil Case No. 6707, in which Maxima received one-half of all conjugal assets. Plaintiffs did not challenge that partition, relying instead on Exhibit A. After Maxima died on October 5, 1956, her own will granted only fractional legacies to some heirs of Simeon Blas and nothing t Case Digest (G.R. No. L-14070) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and marriages
- Simeon Blas first married Marta Cruz before 1898; they had three children, only Eulalia left descendants (Maria Gervacio Blas, Marta Gervacio Blas, Lazaro Gervacio Blas and Lazaro’s three children).
- Marta Cruz died in 1898; in 1899 Simeon Blas married Maxima Santos without prior liquidation of conjugal properties from his first marriage.
- Will of Simeon Blas and Exhibit “A”
- On December 26, 1936, Simeon Blas executed a will valuing his conjugal assets at ₱678,880 and declaring by law one-half to belong to his wife Maxima as her conjugal share.
- On the same date Maxima signed Exhibit “A,” agreeing (a) to respect her husband’s will; and (b) to devise one-half of her conjugal share, when she later made her own will, to the heirs and legatees named in Simeon’s will.
- Testimony of Andres and Avelino Pascual and Leoncio Gervacio shows Exhibit “A” was prepared at Simeon’s instance as a compromise to avert heirs of his first marriage from demanding liquidation of unseparated conjugal properties.
- Administration and subsequent events
- Simeon Blas died January 9, 1937; Maxima, as administratrix, submitted inventory (June 2, 1937) and on March 14, 1939 a partition project adjudicating her one-half conjugal share. Plaintiffs did not object, relying on Exhibit “A.”
- Maxima died October 5, 1956; her will did not effectuate the promise in Exhibit “A.”
- Plaintiffs filed suit December 27, 1956 against the administratrix to enforce Exhibit “A” and recover one-half of the properties; the trial court dismissed the complaint and counterclaims.
Issues:
- Nature and validity of Exhibit “A”
- Is Exhibit “A” a valid contract (compromise or otherwise) supported by consideration?
- Does Exhibit “A” infringe the prohibition against contracts on future inheritance (Art. 1271, old Civil Code)?
- Extent of enforceable rights
- Did the subsequent administration and partition of Simeon’s estate bar plaintiffs’ action (res judicata or estoppel)?
- Has prescription or delay extinguished plaintiffs’ right to enforce Exhibit “A”?
- Did Maxima substantially comply with Exhibit “A” in her own will?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)