89. TOMAS CORPUS VS. CORPUS/ADMINISTRATOR 3.

Pursuant to the order of the probate court, a project of partition was submitted
GR No. L-22469, October 23, 1978 – Intestacy
DOCTRINE: Under Article 992, there is no reciprocal succession between legitimate
and illegitimate relatives. A legitimate child is barred from inheriting ab intestate from
an illegitimate uncle.
NOTE: To avoid confusion, this case deals with the successional relationship between
Juanita and Teodoro, thus the doctrine stated above applies to her, and not to petitioner
Tomas who is merely claiming on her behalf.
FACTS
1. Ramona Arguelles and Tomas Corpus (Not Petitioner) were married, with 5
children: Pablo, Jose, and 3 others. When Tomas died, Ramona wed Luis
Rafael Yangco and had 4 recognized acknowledged natural children, one of
them was the decedent Teodoro Yangco (Testator).
2. Teodoro Yangco died. At the time of his death, he had no forced heirs. He
only had:
o His half-brother (Luis Yangco),
o Half-sister (Paz Yangco), wife of Miguel Ossorio,
o The children of his half-brother Pablo Corpus (Amalia, Jose and
Ramon Corpus) and
o The daughter of his half-brother Jose Corpus (Juanita Corpus).
Juanita died in 1944. Represented by Tomas Corpus (Petitioner)
by the administrator and the legatees named in the will. The said project was
contested by the following, on the following grounds (oppositors):
o Estate of Luis Yangco (Half-brother): intestacy should be declared
because the will does not contain an institution of heir.
o Juanita Corpus et al.: the proposed partition was not in conformity
with the will as the testator intended that the estate should be
conserved and not physically partitioned.
4. Nevertheless, the project of partition was approved by the Probate court, in
essence holding that the testator did not really intend to include a perpetual
prohibition against alienation when he stated that some of his estate be
conserved.
5. Oppositors appealed to SC but appeal dismissed after the legatees and the
appellants entered into compromise agreements wherein the legatees agreed
to pay the heir of Juanita Corpus – her son Tomas Corpus (Petitioner). For
the estate of Luis Yangco, a similar compromise agreement was entered. The
dismissal of the appeal became final and executory.
6. Pursuant to the compromise agreement, Tomas Corpus signed a receipt
acknowledging that he received from the Yangco estate P2k as “settlement in
full of my share of the compromise agreement as per understanding with
Judge Roman Cruz, our attorney in this case”.

Ramona Luis Rafael 7. The legatees executed an agreement for the settlement and physical partition
Tomas Corpus
Arguelles Yangco of the Yangco estate which was approved by the probate court in 1949. 1945
project of partition was pro tanto modified.

Pablo (Dead) Jose Teodoro 8. Tomas Corpus still filed action to recover Juanita’s supposed share in
(Testator) Yangco’s intestate estate, alleging that the dispositions in Yangco’s will
Luis
contained perpetual prohibitions on alienation which rendered it void under
Amalia Juanita Paz Article 785, Old Civil Code and that 1949 partition is invalid. The decedent’s
Jose Luisa estate should have been distributed according to the rules on intestacy.
Ramon
Tomas ISSUE

WON Juanita Corpus was a legal heir of Teodoro Yangco allowing her to receive
NOTE: The children of Luis Yangco are acknowledged natural children, meaning money through an intestate share in the estate? NO.
they are considered to be illegitimate under law.
HELD

 The Supreme Court ruled that Juanita is not a legal heir because there is no
reciprocal succession between legitimate and illegitimate relatives.

 Under Article 992 an illegitimate child has no right to inherit ab intestate from
the legitimate children and relatives of his father or mother; nor shall such
children or relatives inherit in the same manner from the illegitimate child.

 Article 992 is based on the theory that the illegitimate child is disgracefully
looked upon by the legitimate family while the legitimate family is, in turn,
hated by the illegitimate child.

 Since Teodoro R. Yangco was an acknowledged natural child or was

illegitimate and since Juanita Corpus was the legitimate child of Jose
Corpus, himself a legitimate child, we hold that appellant Tomas Corpus
has no cause of action for the recovery of the supposed hereditary share
of his mother, Juanita Corpus, as a legal heir, in Yangco's estate.

 Juanita Corpus was not a legal heir of Yangco because there is no reciprocal
succession between legitimate and illegitimate relatives. The trial court did
not err in dismissing the complaint of Tomas Corpus.

 In default of natural ascendants, natural and legitimated children shall be

succeeded by their natural brothers and sisters in accordance with the rules
established for legitimate brothers and sisters."

 Hence, Teodoro R. Yangco's half-brothers on the Corpus side, who were

legitimate, had no right to succeed to his estate under the rules of
intestacy.

WHO WON? RESPONDENT CORPUS