Title
IN RE: Satillon vs. Miranda
Case
G.R. No. L-19281
Decision Date
Jun 30, 1965
Pedro Santillon died intestate; surviving spouse Perfecta and son Claro disputed estate division. Court ruled equal shares under Article 996, affirming 1/2 each after deducting conjugal share.
A

Case Digest (G.R. No. L-19281)

Facts:

  • Death of Decedent and Parties
  • On November 21, 1953, Pedro Santillon died intestate in Tayug, Pangasinan, leaving as compulsory heirs his wife, Perfecta Miranda, and his only son, Claro Santillon.
  • During the marriage, Pedro acquired several parcels of land in Pangasinan, some claimed by Perfecta as exclusive and others as conjugal.
  • Administration Proceedings and Lower Court Order
  • Claro Santillon filed a petition for letters of administration. Oppositors Perfecta Miranda and spouses Benito U. Miranda and Rosario Corrales contested, alleging the properties were conjugal (except three parcels), that Perfecta had conveyed ¾ of her undivided share to Benito and Rosario, that administration was unnecessary due to a pending partition case, and that Perfecta was better qualified as administratrix.
  • Perfecta was appointed administratrix; on March 22, 1961, the court tasked commissioners to draft a partition and distribution project.
  • On April 25, 1961, Claro moved to declare the heirs’ shares under Art. 892 (testamentary legitime), claiming he was entitled to ¾ and Perfecta to ¼. Perfecta countered under Art. 996 (intestate succession), claiming equal shares (½–½).
  • On June 28, 1961, the Court of First Instance ordered the estate divided equally: ½ to Perfecta and ½ to Claro, after deducting the conjugal share. Claro appealed.

Issues:

  • Whether the June 28, 1961 order of the Court of First Instance is final and appealable.
  • How an intestate estate is to be divided when the only survivors are the spouse and one legitimate child.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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