Title
Intestate Estate of Rosales vs. Rosales
Case
G.R. No. L-40789
Decision Date
Feb 27, 1987
A surviving spouse is not an intestate heir of a parent-in-law; inheritance rights are limited to descendants by blood or representation.

Case Digest (G.R. No. L-40789)
Expanded Legal Reasoning Model

Facts:

  • Decedent’s profile and family relations
    • On February 26, 1971, Petra V. Rosales died intestate in Cebu City.
    • She was survived by her husband, Fortunato T. Rosales, and two children, Magna Rosales Acebes and Antonio Rosales.
    • A third child, Carterio Rosales, predeceased the decedent; he had one child, Macikequerox Rosales, and was survived by his widow, Irenea C. Rosales (the petitioner).
  • Settlement proceedings in the Court of First Instance of Cebu
    • On July 10, 1971, Magna Rosales Acebes filed Special Proceedings No. 3204-R to settle the estate (gross value: ₱30,000.00) and was appointed administratrix.
    • By Order dated June 16, 1972 (reiterated February 4, 1975), the trial court declared as legal heirs of Petra Rosales and fixed their shares:
      • Fortunato T. Rosales (husband) – 1/4
      • Magna Rosales Acebes (daughter) – 1/4
      • Macikequerox Rosales (grandson) – 1/4
      • Antonio Rosales (son) – 1/4
  • Petitioner’s claim and trial court’s denial
    • Irenea C. Rosales claimed a share of her mother-in-law’s estate as the surviving spouse of Carterio, asserting she was a compulsory heir together with her son.
    • The trial court denied her motion for reconsideration, prompting this petition for review.

Issues:

  • Is a widow (surviving spouse) an intestate heir of her mother-in-law?
  • Are the trial court’s orders excluding the widow from the estate final as against her?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.