Facts:

The case involves Rafael Reyes, the executor of the estate of Luz Ciria de Reyes, as the plaintiff and appellant, and Manuel Ciria y Vinant as the defendant and appellee. The proceedings originated from the probate of the will of the deceased Luz Ciria de Reyes in the Court of First Instance in Manila. On October 2, 1912, the court declared Manuel Ciria y Vinant to be an heir of Luz Ciria by law, granting him a right to one-sixth of the conjugal partnership property between Luz Ciria and Rafael Reyes. Following this declaration, Rafael Reyes filed an appeal against the decision, seeking to include all evidence presented during the probate proceedings in the appeal record. However, Manuel Ciria's counsel objected, arguing that the appeal was premature and that the judgment was not final, as it did not specify the total hereditary property or the exact shares of the heirs. The cou...

Facts:

1. Probate Proceedings: The case involves the probate of the will of the deceased Mrs. Luz Ciria Reyes. Rafael Reyes, the executor of her estate, appealed the decision of the Court of First Instance dated October 2, 1912, which declared Manuel Ciria y Vinant as an heir by force of law and entitled to one-sixth of the conjugal partnership property.
2. Appeal and Objections: Rafael Reyes requested the inclusion of all proofs submitted in the probate proceedings in the transcript for appeal. Manuel Ciria objected, arguing that the appeal was improper because the judgment was not final, as it did not include a statement of the hereditary property or the proportional share for each heir.
3. Judgment of the Lower Court: The lower court declared Manuel Ciria y Vinant as an heir of Luz Ciria Reyes and entitled to one-sixth of the conjugal partnership property. The court also issued a supplementary order on October 28, 1912, confirming this share.
4. Appealability of the Judgment: The main issue was whether the judgment of October 2, 1912, supplemented by the order of October 28, 1912, was final and thus appealable.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Finality of Declaratory Judgments: A judgment declaring heirship and the proportional share of the estate is final and appealable under Section 782 of the Code of Civil Procedure, even if the actual partition of the estate has not yet been completed.
2. Purpose of Section 782: Section 782 allows appeals from judgments determining controversies over heirship and distributive shares, ensuring that such issues are resolved before the final distribution of the estate.
3. Efficiency in Probate Proceedings: The court emphasized that delaying the appeal until after the partition of the estate would be inefficient and unjust, as the partition depends on the resolution of the heirship controversy.
4. Compliance with Legal Requirements: The judgment complied with Section 782 by declaring the heir and his proportional share, even though it did not include a detailed partition of the estate. The court held that the judgment was sufficient to resolve the controversy over heirship, making it final and appealable.

Concurring and Dissenting Opinions

• Concurring Opinion (Moreland, J.): Justice Moreland concurred, emphasizing that Section 782 is clear and mandatory, and that the appeal was proper under its provisions. He cited previous cases where similar appeals were allowed.
• Dissenting Opinion (Trent, J., with Johnson, J.): Justice Trent dissented, arguing that the judgment was not final because it did not include a detailed partition of the estate. He contended that the appeal should be dismissed, and the lower court should proceed with the distribution of the estate in accordance with the law.

Conclusion:

The Supreme Court allowed the appeal to proceed, holding that the judgment declaring heirship and the proportional share of the estate was final and appealable. The court rejected the argument that the appeal was premature and emphasized the importance of resolving heirship controversies before the final distribution of the estate.