Title
Nieva vs. Alcala
Case
G.R. No. 13386
Decision Date
Oct 27, 1920
Segunda Maria Nieva, an acknowledged natural daughter, sought inheritance under reserva troncal but was denied as Article 811 applies only to legitimate relatives.
A

Case Digest (G.R. No. 13386)

Facts:

On April nineteen, eighteen eighty-nine, Juliana Nieva died intestate. Before her death, she had been married to Francisco Deocampo, and of that marriage Alfeo Deocampo was born. Juliana’s intestate estate passed to her son, Alfeo, by operation of law, and included the parcels of land described in Paragraphs V and X of the complaint. Alfeo subsequently died intestate and without issue on July seven, eighteen ninety, so the same parcels passed by intestate succession to his father, Francisco Deocampo. Thereafter, Francisco Deocampo married the defendant Manuela Alcala, and their son, the defendant Jose Deocampo, was born as a minor. Upon Francisco’s death on August fifteen, nineteen fourteen, Manuela and Jose took possession of the parcels under the claim that Jose had inherited them ab intestate from his deceased father. On September thirty, nineteen fifteen, the plaintiff Segunda Maria Nieva, invoking Article 811 of the Civil Code, instituted an action to recover the same parcels, alleging that she was an acknowledged natural daughter of Juliana Nieva. The Court of First Instance of the Province of Tayabas absolved the defendants from all liability on the ground that, even assuming arguendo that the plaintiff was an acknowledged natural daughter, she was not entitled to the reserva troncal under Article 811 because she was an illegitimate relative. The appeal raised first the question of the plaintiff’s status and, second, whether an illegitimate relative within the third degree could benefit from Article 811.

Issues:

Whether Segunda Maria Nieva was entitled to recover the parcels by reason of the reserva troncal under Article 811 of the Civil Code as an acknowledged natural daughter and illegitimate relative within the third degree.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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