Title
Corpus vs. Corpus
Case
G.R. No. L-22469
Decision Date
Oct 23, 1978
Teodoro Yangco, an acknowledged illegitimate child, left a will probated in 1939. His legitimate relatives, including Juanita Corpus, contested inheritance rights. The Supreme Court ruled that illegitimate and legitimate relatives cannot reciprocally inherit under Article 992, affirming the trial court's dismissal.

Case Summary (G.R. No. L-22469)

Applicable Constitution

Decision date: October 23, 1978. The applicable constitutional framework at the time of decision is the 1935 Constitution of the Republic of the Philippines (i.e., the pre‑1987 constitutional regime).

Procedural History — Probate and Early Appeals

Teodoro Yangco’s will was probated in CFI Manila (Special Proceeding No. 54863) and probate decree was affirmed by this Court in 1941. Pursuant to probate court order, a project of partition dated November 26, 1945 was submitted by the administrator and legatees. The project was opposed by the estate of Luis R. Yangco (arguing intestacy because the will allegedly lacked an institution of heir) and by counsel for Juanita Corpus (arguing the will intended to “conserve” property rather than permit physical partition). The probate court approved the 1945 partition project on December 26, 1946, finding no legal ground to declare intestacy. Appeals from that order were dismissed after compromise agreements in October 1947; entries of judgment became final on October 14 and November 4, 1947.

Compromises, Receipts, and the 1949 Agreement

Under the 1947 compromise, legatees agreed to pay sums (including P35,000) to various claimants; Tomas Corpus signed the compromise as sole heir of Juanita Corpus and later signed a receipt (Oct. 24, 1947) acknowledging P2,000 received “as settlement in full.” On September 20, 1949, legatees executed an agreement for settlement and physical partition of the Yangco estate, which the probate court approved and which modified the 1945 partition pro tanto.

Plaintiff’s Suit and Trial Court Disposition

On October 5, 1951, Tomas Corpus, as sole heir of Juanita Corpus, filed suit in CFI Manila to recover what he asserted to be Juanita’s share of Yangco’s intestate estate, contending the will’s perpetual alienation prohibitions were void under article 785 (Spanish Civil Code) and that the 1949 partition was invalid, thus necessitating intestate distribution. The trial court (decision July 2, 1956) dismissed the action on grounds of res judicata and laches and held that the will’s intrinsic validity had already been passed upon by the probate court’s December 26, 1946 order approving partition.

Certification and Issues on Appeal

The Court of Appeals certified the appeal to this Court (CA resolution Jan. 23, 1964) because the controversy involved real property valued above the jurisdictional threshold. Appellant raised three principal errors: (1) that Teodoro R. Yangco was a natural (illegitimate) child rather than legitimate; (2) that Yangco’s will was not duly legalized; and (3) that plaintiff’s action was not barred by res judicata and laches. The Supreme Court stated it was unnecessary to resolve all three questions to dispose of the appeal.

Central Legal Question and Approach

The dispositive question was whether Juanita Corpus was a legal heir of Teodoro Yangco such that Tomas (her son) could seek recovery of an intestate share. Resolution required determining Yangco’s filiation (i.e., whether he was legitimate or an acknowledged natural child), because succession between legitimate and illegitimate relatives is governed by exclusionary rules under the Civil Code.

Filiation Evidence and Presumptions

The trial court had found Yangco to be an acknowledged natural child based largely on the will of Luis R. Yangco (dated June 14, 1907), which expressly declared four “hijos naturales reconocidos” including Teodoro. The Court held the authenticity and probative value of that document (part of the official probate record and reproduced as Exhibit 1) to be incontestable. Although appellant invoked the presumption of legitimacy (semper praesumitur pro matrimonio) and other secondary assertions (e.g., a biographical statement suggesting different marriages), the Supreme Court found no merit in attacking the public judicial record that recognized Teodoro as an acknowledged natural child.

Legal Effect of Illegitimacy on Succession

Applying article 943 of the old Civil Code (now article 992 of the Civil Code), the Court emphasized the settled rule that there is no reciprocal intestate succession between legitimate and illegitimate relatives: an illegitimate (natural or legitimated) child cannot inherit ab intestato from legitimate children and relatives of the parent, and vice versa. The Court cite

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