G.R. No. 215195 - People vs. Descartin, Jr. y Mercader

Eugeniano Saarenas, the owner of the three parcels of land in the City of Cagayan de Oro, died intestate in 1937 leaving no ascendants or descendants.
At the time of his death, no formal will was executed, and the decedent did not have legitimate children, which would have otherwise taken priority in the succession.

Plaintiffs (Eugenia Morales et al.) are illegitimate (adulterous) children of Eugeniano Saarenas, born between 1910 and 1927. They filed the complaint for the recovery of the disputed lands.
Defendant Proceso Yanez, along with his sisters, took possession of the parcels as they are the surviving nephews (by a sister) of Eugeniano Saarenas.
Plaintiffs based their claim on New Civil Code provisions (specifically arts. 287 and 988) that, for the first time, granted successional rights to illegitimate children in the absence of ascendants and descendants.
Defendant Yanez and his sisters maintained that their right to inherit should be determined under the old Civil Code (specifically arts. 946, 947, and 948) which did not recognize such rights for illegitimate children.

The trial court, led by Judge Jose P. Veluz of the Court of First Instance of Misamis Oriental, dismissed the plaintiffs’ complaint.
The trial judge adhered to existing jurisprudence exemplified by the decision in Uson vs. Del Rosario (92 Phil., 530), which addressed the retroactive application of new rights under the Civil Code.
The legal question centered on whether the new successional rights of illegitimate children, as provided by the New Civil Code (effective June 1950), could be applied retroactively to a decedent (Eugeniano Saarenas) who died in 1937, and whether these new rights would prejudice the vested rights acquired under the old legislation.

Under the New Civil Code, particularly Article 2253, new rights declared in the Code are effective immediately—even if the act or event giving rise to the right occurred under previous laws—provided that no vested or acquired right is impaired.
The incumbent right of ownership vested in Maria Uson in 1945, upon the death of her husband, based on Article 657 of the old Civil Code, which commands that successional rights are transmitted immediately upon death.
Article 2263 of the New Civil Code explicitly states that the inheritance of persons who died before its effectivity (even if they died with or without a will) shall be governed by the prior Civil Code and applicable laws.

Whether the right of illegitimate children to inherit, as stipulated in arts. 287 and 988 of the New Civil Code, should apply retroactively to a decedent who died in 1937.
Whether the retroactive application of the New Civil Code's provisions would prejudice or impair any vested rights that were acquired under the old Civil Code.

Which legal regime should govern the succession matter: the New Civil Code (enacted in 1949 and effective from June 1950) or the old Civil Code, since the decedent died prior to the new law’s effectivity.
Whether the established vested rights in favor of previous inheritors (as demonstrated by case precedents and Article 657 of the old Civil Code) are to be preserved over the newly recognized rights for illegitimate children.