G.R. No. 14856 - Florentino vs. Florentino

Case Summary (G.R. No. 14856)

Case Background and Relevant Dates

After the death of Apolonio Isabelo Florentino II in 1890, his eleven children inherited his estate as provided by his will. The posthumous son, Apolonio Florentino III, received certain properties marked in the complaint as reservable property. Apolonio Florentino III died in 1891, and his mother, Severina Faz de Leon, inherited his estate. Upon Severina’s death in 1908, Mercedes Florentino, her only surviving daughter and forced heir, inherited all property including that which originated from Apolonio Florentino III.

Legal Issue Presented

The principal legal question centers on whether the property inherited by Severina Faz de Leon from her son Apolonio Florentino III retained the character of reservable property under Article 811 of the Civil Code, obliging Severina and subsequently her heirs to reserve such property for the benefit of other relatives within the third degree of kinship of the deceased Apolonio Florentino III. The case also examines whether the existence of a forced heir (Mercedes Florentino) negates the obligation to reserve property for other entitled relatives.

Applicable Law: Article 811 of the Civil Code

Article 811 of the Civil Code provides that any ascendant who gratuitously inherits property from a descendant must reserve such property for the benefit of relatives within the third degree related to the line from which the property originated. The ascendant holds only the enjoyment or usufruct of such property, which must be preserved and eventually delivered to the designated reservatarios (entitled relatives). The property remains reservable unless all eligible relatives within the third degree die, after which the property becomes free and may be treated as the ascendant’s own.

Facts Concerning Family Relations and Property Transmission

Apolonio Florentino III inherited certain property from his father, Apolonio Isabelo Florentino II.
After Apolonio Florentino III’s death, his mother Severina Faz de Leon inherited this property.
Severina held the property under fiduciary obligation as reservable property for the relatives of her deceased son within the third degree.
Upon Severina’s death, her daughter and forced heir Mercedes Florentino inherited the property, including the reservable property acquired from Apolonio Florentino III.
Plaintiffs are other children and descendants of Apolonio Isabelo Florentino II within the third degree of kinship to the deceased Apolonio Florentino III, including half-siblings and nephews, thus qualifying as reservatarios entitled to a share of the property.

Trial Court’s Ruling and Defendant's Arguments

The trial court absolved the defendants on the basis that Article 811 was inapplicable because Mercedes Florentino, as the forced heir of Severina Faz de Leon, lawfully inherited the property without it passing to outsiders, hence no need for reservation for other relatives. It held that Severina’s obligation to reserve property could not override Mercedes’s legitime (forced share), thus upholding Mercedes's exclusive inheritance right. The defendants relied on the theory that the doctrine preventing property from passing to strangers was fulfilled since the property remained within the legitimate family line and that enforcing reservation would violate the forced heir’s rights.

Supreme Court’s Legal Analysis

The Supreme Court examined whether the property retained its reservable nature when it passed from Apolonio Florentino III to his mother Severina and subsequently to Mercedes. The Court held that:

The property unquestionably originated from the common ancestor, Apolonio Isabelo Florentino II, and passed by inheritance to Apolonio Florentino III, then to Severina.
Severina, as an ascendant inheriting from her descendant Apolonio III, was under legal obligation to preserve and reserve the property for relatives within the third degree of the line from which it came, in accordance with Article 811.
Severina held only usufruct or fiduciary rights, not outright ownership, in relation to reservable property; ownership remained in those entitled to reservation.
Reservation rights existed despite Severina's status as widow and forced heir of Apolonio Isabelo, as well as Mercedes’s role as forced heiress of Severina.
Reservable property does not become part of the forced heir’s legitime until all reservatarios within the third degree cease to exist; thus, Mercedes cannot legally exclude other relatives from their rightful shares.

On Right of Representation and Entitlement of Plaintiffs

The Court confirmed that the plaintiffs, being first-degree relatives and representatives of deceased siblings within the third degree of kinship, qualify as reservatarios. Their right to participate in the reservable property is personal and exclusive, excluding more remote relatives beyond the third degree. Representation is valid among the third degree, allowing children of deceased relatives to stand in their place.

Conclusion on the Obligation to Reserve and Transfer of Property

Severina Faz de Leon failed to fulfill her fiduciary duty to reserve and preserve the property for the reservatarios.
Mercedes Florentino’s inheritance of the reservable property does not extinguish the rights of the other entitled relatives; the property did not lose its reservable character upon Severina’s death.
The attempted testamentary disposition by Severina in favor of Mercedes, insofar as it concerns reservable property, is void and m

Case Syllabus (G.R. No. 14856)

Facts of the Case

Apolonio Isabelo Florentino II married twice: first to Antonia Faz de Leon, by whom he had nine children, and second to Severina Faz de Leon, by whom he had two children, including the posthumous son Apolonio Florentino III.
Upon Apolonio Isabelo’s death in 1890, his eleven children, including the posthumous Apolonio III, inherited his estate according to a will that declared all his property should be divided among all his children.
Apolonio Florentino III inherited specific property as his share, including lands, livestock, personal property, and valuable objects.
Apolonio Florentino III died in 1891 without issue, and his mother Severina Faz de Leon inherited his property.
Severina Faz de Leon died in 1908, leaving a will that appointed her only living daughter, Mercedes Florentino, as universal heir, who then took possession of all her mother’s property, including that inherited from Apolonio III.
The plaintiffs, composed of children and grandchildren of Apolonio Isabelo from his first marriage, claimed their right as reservatarios to portions of the reservable property that came through Apolonio III to Severina and then to Mercedes.
Plaintiffs allege defendants withheld their respective shares and fruits of the land, causing damages and unjust enrichment.

Issues Presented

Whether the property inherited by Severina Faz de Leon from her deceased son Apolonio Florentino III constituted reservable property under Article 811 of the Civil Code.
Whether Severina, as ascendant heir, was obligated to reserve this property for the benefit of relatives within the third degree of the descending line from which the property originated.
Whether Mercedes Florentino, as forced heiress of Severina, obtained absolute ownership of the reservable property, or if the plaintiffs, as relatives of Apolonio III within the third degree, have a right to the property or its fruits.
The applicability of Article 811 in protecting property from passing to strangers outside the line of succession.
Whether Severina’s obligation to reserve the property conflicts with the legitime rights of her forced heir, Mercedes Florentino.
Determination of the extent of plaintiffs’ entitlement to the property and to the fruits or rents collected from it.

Relevant Legal Provisions and Principles

Article 811 of the Philippine Civil Code: Any ascendant who inherits property from a descendant acquired gratuitously from a common line must reserve such property for relatives within the third degree of that line.
Reservable property does not vest absolute ownership in the ascendant inheriting it but rather grants a fiduciary or usufructuary right, with an obligation to preserve and return it to qualified reservatarios.
The right of representation applies only to reservatarios within the third degree who represent deceased relatives entitled to reservation rights.
Forced heirs (legitime) cannot be deprived of their legitime or burdened except as expressly allowed by law (Article 813 of the Civil Code).
Reservable property remains distinct from the forced heir’s legitime until all reservatarios die, after which it becomes free property.
The presence of a forced heir in the ascendant’s estate does not extinguish the reservation obligation nor the reservable character of inherited property.

Contentions of the Parties

Plaintiffs contend that the property inherited by Severina from her son Apolonio III retained its status as reservable property under Article 811, obligating Severina and subsequently Mercedes to reserve and return shares to relatives of Apolonio III within the third degree, including themselves.
Plaintiffs assert their right to receive one-seventh of the fruits of the property from Mercedes and demand delivery of their shares or p