Case Summary (G.R. No. L-14070)
The Promise in Exhibit A and Its Circumstances
On December 26, 1936, Simeon directed the preparation of Exhibit A, signed by Maxima Santos, in which she acknowledged her husband’s will and promised on her honor to devise, in her own testament, one-half of her conjugal share to the heirs and legatees named in Simeon’s will. The document was executed to prevent litigation over the unliquidated first conjugal partnership.
Proceedings Below and Trial Court Ruling
Plaintiffs sued the administratrix of Maxima’s estate to enforce the promise in Exhibit A and recover P50,000 in damages. The trial court dismissed the complaint, holding that Exhibit A lacked consideration, was not a valid contract or will, dealt with future inheritance, and was unenforceable. Counterclaims and cross-claims were likewise dismissed.
Issues on Appeal: Nature and Enforceability of Exhibit A
The Supreme Court faced the question whether Exhibit A constituted:
- A valid compromise or contract with sufficient consideration to avoid litigation over conjugal assets;
- A prohibited pactum successorium on future inheritance as barred by Article 1271 of the old Civil Code;
- A basis for specific performance and damages.
Exhibit A as Compromise under Article 1809, Spanish Civil Code
The Court held that Exhibit A is a compromise agreement: each party relinquished certain claims (the first-marriage heirs abandoned liquidation proceedings, and Maxima bound herself to future disposition). This pact avoided protracted litigation and had adequate consideration—the mutual forbearance of rights over existing conjugal properties acquired by Simeon.
No Violation of the Prohibition on Contracts Over Future Inheritance
Article 1271 prohibits contracts on the universal or fractional estate “to be acquired” at death. Exhibit A, however, concerned specific, existing conjugal assets defined in Simeon’s will; it did not contemplate an indefinite future estate. Consequently, it fell outside the statutory ban on agreements over future inheritance.
Partition Proceedings and Prescription Do Not Bar the Action
The heirs by the first marriage failed to contest the partition of Simeon’s estate—approved in 1939—because they relied on Exhibit A. Their cause of action to enforce Exhibit A arose only upon Maxima’s death in 1956, when she failed to carry out her promise. The complaint, filed on December 27, 1956, was timely under Article 1969 (old Civil Code), and the partition decree did not extinguish the contractual obligation.
Non-Compliance and Remedy Ordered
Analys
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Case Background
- Supreme Court decision in G.R. No. L-14070, March 29, 1961, reported at 111 Phil. 503
- Appeal from the Court of First Instance of Rizal, SP. Proc. No. 2524
- Plaintiffs and appellants seek judicial declaration and recovery of properties promised by will and Exhibit “A”
- Defendant and appellee (administratrix) moved to dismiss; also counterclaimed for damages
Parties and Relationships
- Simeon Blas’s first marriage to Marta Cruz produced three children; only Eulalia left descendants
- Simeon’s second marriage to Maxima Santos on June 28, 1898; no liquidation of first conjugal properties
- Plaintiffs: Maria Gervacio Blas, Manuel Gervacio Blas, Leoncio Gervacio Blas, Loida Gervacio Blas
- Defendants/appellants: Marta Gervacio Blas and Dr. Jose Chivi
- Defendant/appellee: Rosalina Santos, special administratrix of Maxima Santos’s estate
Facts of the Marital Estates
- Properties from the first marriage remained unliquidated and included in second conjugal mass
- Conjugal wealth from second marriage assessed at P678,880.00 by Simeon’s will
- Simeon died January 9, 1937; Maxima appointed administratrix of his estate on June 2, 1937
Simeon Blas’s Testamentary Provisions
- Will dated December 26, 1936, prepared by Andres Pascual with Avelino Pascual’s assistance
- Declared total conjugal acquisitions (lands, fishponds, other properties) valued at P678,880.00
- Recognized that one-half of conjugal assets, after debts, belongs to wife Maxima Santos under law
Preparation and Contents of Exhibit “A”
- Document executed by Maxima Santos on December 26, 1936; offered as Exhibit “A” at trial
- Acknowledged reading and understanding Simeon’s will, pledged to respect every disposition
- Promised to give one-half of her share in their properties to heirs and legate