G.R. No. 232663 - Commissioner of Internal Revenue vs. Spouses Magaan

Benito Legarda y De la Paz died in Manila on June 17, 1933, survived by his widow, Filomena Roces, and seven children (Beatriz, Rosario, Teresa, Filomena, Benito, Alejandro, José).
On July 12, 1939, the real properties of Benito Legarda y Tuason (father of the deceased) were partitioned into three equal shares among his daughters Consuelo and Rita, and the heirs of the deceased son Benito Legarda y De la Paz (represented by Benito F. Legarda).

Filomena Legarda y Roces died intestate and without issue on March 19, 1943; her sole heiress was her mother, Filomena Roces Vda. de Legarda.
By extrajudicial affidavit of May 12, 1947, Filomena Roces adjudicated to herself the properties inherited from her daughter, consisting of:

A savings deposit (₱3,699.63) in the National City Bank of New York.
Shares in Benguet Consolidated Mining Co. and fractional interests in various corporations.
Proportional interests in multiple realty titles (TCT Nos. 80226, 80237–80243, 80260, 80261, 57512, 48164, 84714, 48201–48206, 48160, 48192, 4475, 966, 41862, 50495, 48161, 48163, 48199, 57551, 13458) across Metro Manila, Rizal, Baguio, and Tayabas.

On March 6, 1953, Filomena Roces executed handwritten documents distributing the inherited properties to sixteen grandchildren (children of her sons Benito, Alejandro, José), with specific exceptions.
Between July 1958 and February 1959, Mrs. Legarda and her six surviving children partitioned properties representing one-third of the share in their father’s estate.
Filomena Roces died on September 22, 1967; her holographic will was probated July 16, 1968, in CFI Manila (Special Proceeding No. 70878) and affirmed by the Court of Appeals (G.R. No. 43480-R, July 30, 1976).
On May 20, 1968, Beatriz L. Gonzalez moved to exclude from her mother’s estate inventory the properties inherited from her sister Filomena Legarda, claiming they were reservable under Article 891 C.C.; opposed by the administrator.
Without waiting for resolution, Gonzalez filed on June 20, 1968, a civil action for partition, accounting, reconveyance, and damages, seeking declaration of reserva troncal over the disputed properties.
The Court of First Instance of Manila dismissed her complaint; Gonzalez appealed under R.A. 5440 to the Supreme Court.

Whether the properties inherited by Filomena Roces from her daughter, Filomena Legarda, are reservable under Article 891 of the Civil Code (reserva troncal).
Whether a reservor (Filomena Roces) may dispose mortis causa of such reservable properties to her grandchildren, excluding her own children who are reservees in a nearer degree.