Title
Blas vs. Santos
Case
G.R. No. L-14070
Decision Date
Mar 29, 1961
Simeon Blas’ heirs sued Maxima Santos’ estate for failing to fulfill her promise in Exhibit "A" to leave half her conjugal share to them. The Supreme Court ruled the promise was enforceable, ordering compliance.

Case Digest (G.R. No. L-14070)
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)

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