Title
Austria vs. Reyes
Case
G.R. No. L-23079
Decision Date
Feb 27, 1970
Basilia’s will upheld; adoption’s validity irrelevant to heir institution. Nephews’ intervention limited; no intestacy rights over willed properties.

Case Summary (G.R. No. L-23079)

Procedural History and Nature of Dispute

Basilia’s last will was admitted to probate in Special Proceedings No. 2457, naming five legally adopted children as compulsory heirs and devising the bulk of her estate to them. More than two years later, she died and Perfecto Cruz was appointed executor. The petitioners, as nearest blood relatives, intervened to challenge the validity of the adoptions and to claim intestate succession over the entire estate. The trial court first permitted their intervention without limitation, then confined it to property not disposed of by the will, and denied subsequent motions for reconsideration.

Core Legal Issue

Whether the intervention of nephews and niece may extend to properties devised in the will on the ground that the institution of heirs is intrinsically null due to a false cause—namely, an adoption allegedly spurious—and whether orders limiting their intervention were an abuse of discretion.

Institution of Heirs and False Cause (Civil Code Art. 850)

Article 850 provides that if a will states a false cause for instituting an heir, that statement is to be disregarded unless the will shows the testator would have omitted the institution had they known of the falsity. The requisites for annulment under Art. 850 are:

  1. The will must expressly state the cause for institution.
  2. The stated cause must be proved false.
  3. The face of the will must indicate the testator would not have proceeded with the institution if aware of the falsity.

Interpretation of the Will and Testator’s Intent

  • The will’s references to “sapilitang tagapagmana” and “sapilitang mana (legitime)” reflect statutory terminology but do not unequivocally reveal that the testatrix believed she was compelled by law to name those heirs because of lawful adoption.
  • The will does not specify any particular motive beyond naming the adopted children as compulsory heirs.
  • There is no clear indication that, had Basilia known the adoptions were spurious, she would have revoked their institution.
  • Dispositions of the free portion of her estate demonstrate a strong intention to benefit the respondents beyond the compulsory share.

Policy Favoring Testacy and Avoidance of Intestacy

Philippine law favors upholding a testator’s will and avoiding intestacy. Doubts in interpretation are resolved to give effect to every expression, prevent intestacy, and honor the testator’s evident purpose to dispose of practically the whole estate.

Collateral Attack on Adoption

The legitimacy of the adoptions may only be challenged in a direct, separate action and cannot serve as a basis for collateral nullification of the institution of heirs in probate proceedings.

Trial Court’s Exercise of Discretion over Intervention

Under the Rules of Court, the trial court properly clarified and limited the scope of intervention to properties not cover

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