G.R. No. L-41480 - Sy vs. Central Bank of the Philippines

The case arises from the appeals filed by the attorneys of Basilisa Salteras, Potenciana de la Cruz, and Benigno Calderon (acting as the natural guardian of minors Maria and Josefa Calderon), as well as counsel for Mauro Sulat, Encarnacion Gutierrez Calderon, Benigno Calderon, and Calixto Salteras.
The appellants challenged an order issued on December 6, 1911, which authorized the administrator, Lucas Eugenio, to convey a property (classified as urban) — a house and lot on Calle Anloague, Binondo (old No. 29; new No. 173) — to Petronila Eugenio based on a petition by Ramon Fabie.

The property in dispute is detailed in the testator’s will of the deceased Miguel Fabie.
Clause 12 of the will specifically directs that the property on Calle Anloague be delivered as a legacy to the testator’s wife, Maria Cristina Calderon, provided that the net revenue is used for the care, education, and assistance of the children of the servants and the two children of D. Lucas y Eugenio (Filomena and Joaquin) while the widow remains alive.
The clause further provides that after the widow’s death, the property should pass on to the persons who served and cared for her, or if she fails to provide for such disposition in her will, then to the testator’s brother Ramon Fabie, or in his default, to his sons, Serafin and Jose.

At trial, evidence was presented regarding who actually rendered service and care to the testator’s widow during her lifetime.
The record established that, apart from Petronila Eugenio (who had been serving in the household while the testator was still alive), several other persons provided useful assistance and companionship to the widow.
The trial judge initially excluded the minor legatees Maria and Josefa Calderon on the basis that they were too young to serve as household helpers; however, evidence showed they, as proteges, regularly accompanied and assisted the widow.

Article 675 of the Civil Code – a provision applicable to the interpretation of wills – was cited, emphasizing the literal understanding of a testamentary provision unless the testator’s clear intent is otherwise demonstrable.
The Supreme Court decisions of Spain (from 1882 to 1903) were also referenced, reiterating that a clearly expressed testamentary intention should be followed as per the literal meaning of the testator’s words.
The case involved determining how exactly the testamentary condition (i.e., assistance rendered to the widow) should be fulfilled and who precisely qualifies as a legatee.

How should the provisions of clause 12, particularly regarding the service and care rendered to the widow, be interpreted in a manner faithful to the testator’s clear intentions?
Is the literal rule, as provided in Article 675 of the Civil Code, sufficient to resolve ambiguities regarding the fulfillment of the testamentary condition?

Who are the rightful recipients of the legacy based on the service provided to the widow?
Should the minor proteges, Maria and Josefa Calderon, be considered capable and eligible to share in the legacy despite their age?

How should the property be disposed of or its proceeds divided so as to satisfy the conditions stipulated in the will?
What is the appropriate remedy if the testator’s wife fails to execute her duty in incorporating these instructions in her own will?