G.R. No. L-22469 - Corpus vs. Corpus

Teodoro R. Yangco died in Manila on April 20, 1939, aged seventy-seven years.
His will dated August 29, 1934, was probated in the Court of First Instance of Manila in Special Proceeding No. 54863.
This Court affirmed the probate decree in 1941 (Corpus vs. Yangco, 73 Phil. 527). The will did not contain an institution of heir.
Yangco had no forced heirs; his nearest relatives included siblings Luis R. Yangco and Paz Yangco, and the children of his half-brothers Pablo and Jose Corpus, including Juanita (Juanita Corpus died in 1944).
Yangco was the son of Luis Rafael Yangco and Ramona Arguelles, the widow of Tomas Corpus. Ramona previously had five children with Tomas Corpus, including Pablo and Jose Corpus.

A project of partition of Yangco's estate was submitted November 26, 1945, by the estate administrator and legatees.
The estate of Luis R. Yangco and others opposed the partition, claiming the will lacked an institution of heir and that the testator intended to conserve the estate rather than authorize partition.
The probate court approved the partition on December 26, 1946, holding that perpetual prohibition on alienation in the will would be disregarded as contrary to law.
The court found no grounds to declare intestacy.

Appeals by Pedro Martinez and others were dismissed in 1947 following compromise agreements, with Tomas Corpus signing as heir of Juanita Corpus and receiving agreed payments.
In 1949, legatees executed a settlement and physical partition of the estate, approved by the probate court, modifying the 1945 project.

On October 5, 1951, Tomas Corpus, on behalf of his deceased mother Juanita Corpus, filed suit to recover Juanita’s supposed intestate share in Yangco’s estate, alleging the will’s prohibitions rendered it void under Article 785 of the Civil Code and that intestate succession should apply.
The trial court dismissed the suit in 1956, ruling the issue was barred by res judicata and laches, and noting the validity of the will had been judicially passed upon.
Tomas Corpus appealed, raising issues including Yangco’s filiation and the validity of the will.

The trial court found that Teodoro R. Yangco was an acknowledged natural child (illegitimate but acknowledged) of Luis Rafael Yangco, based on Luis Rafael’s will dated June 14, 1907, which identified Teodoro and three others as natural recognized children and sole forced heirs.
Tomas Corpus challenged the probative value of this will and argued for the presumption of legitimacy of Teodoro based on remarriage of Luis Rafael Yangco to another woman.
The court found the will authentic and part of public judicial records and that the presumption of legitimacy could be rebutted by such evidence.
Teodoro was therefore deemed illegitimate but acknowledged. Juanita Corpus was a legitimate child of Jose Corpus.

Was Teodoro R. Yangco a legitimate or acknowledged natural (illegitimate) child of Luis Rafael Yangco?
Was the will of Teodoro R. Yangco duly legalized and valid?
Does Tomas Corpus have a legal cause of action to recover the purported intestate hereditary share of his mother Juanita Corpus in Yangco’s estate?
Are the claims of Tomas Corpus barred by res judicata and laches?