G.R. No. 3459
Chiong Joc‑Soy v. Jaime Vañó, et al.

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PARTIES
– Petitioner‑Appellant: Chiong Joc‑Soy legatee named in the will of Genoveva Rosales.
– Respondents‑Appellants: Jaime Vañó and other heirs of Genoveva Rosales; also the appointed Administrator of the estate.

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FACTS: 1. Will of Genoveva Rosales (dated 26 Oct 1903) bequeathed:
– ₱50,000 (Mexican currency) to Chiong Joc‑Soy, ₱20,000 as an absolute legacy and ₱30,000 “for the expenses of interment etc.” of her late husband, Don Nicasio Veloso.
– The remainder of the estate (≈ ₱800,000) to Rosales’ children.

2. The will was proved and allowed by the Court of First Instance (CFI) of Cebu on 24 Nov 1903; an administrator was appointed with a one‑year period to settle debts and legacies.

3. On 6 Feb 1905, Chiong Joc‑Soy filed a petition for settlement of the estate, demanding payment of the ₱50,000 legacy.

4. The CFI, by consent (28 Feb 1905), ordered payment of the ₱20,000 portion.

5. By order of 6 May 1906 (later modified), the court directed the administrator to pay the remaining ₱30,000 (or its Philippine‑peso equivalent) with 6 % interest per annum from 6 Feb 1905.

6. Appeals were filed:
– Administrator & heirs (first error alleged irregularity of will execution; second error failure to require a bond from the legatee).
– Petitioner (challenge to the rate of conversion of Mexican pesos to Philippine currency).

7. No appeal was taken from the probate order itself.

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ISSUE: S

1. Whether the will was validly executed and therefore the legacy to Chiong Joc‑Soy existed.

2. Whether the ₱30,000 portion of the legacy was conditional (i.e., subject to the legatee’s compliance with the testatrix’s desire that the money be expended on the interment of her husband), thus requiring a bond or other security before payment.

3. Whether the legatee is entitled to interest on the ₱30,000 from the date of his demand (6 Feb 1905).

4. What exchange rate should be applied to convert the Mexican‑currency legacy into Philippine currency for payment the rate fixed by the court, the rate prevailing on 6 Mar 1906, or the rate fixed by the Executive Order then in force.

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RULING: (Supreme Court)

1. Validity of the Will The probate court’s admission of the will is conclusive under § 625 of the Code of Civil Procedure. The CFI had jurisdiction to decide the issue of due execution; no party appealed that decision, and no allegation of fraud, mistake, or lack of notice was presented. Consequently, the will is valid, and the legacy exists.

2. Nature of the ₱30,000 Legacy Applying Art. 797, Civil Code, a designation or purpose stated in a will is presumed non‑conditional unless the testatrix clearly intended a binding condition. The clause “for the expenses of interment etc.” expresses a wish or desire, not a legal condition. The Court held that the testatrix did not intend to impose a condition on the legatee; therefore no bond or security is required before payment.

3. Accrual of Interest Following Fuentes v. Canon, a legatee is entitled to interest from the date of demand. Accordingly, the court correctly ordered 6 % per annum from 6 Feb 1905 on the ₱30,000 legacy.

4. Exchange‑Rate Determination The order of 6 May 1906 was interpreted to require payment at the actual market rate of Mexican pesos to Philippine pesos prevailing in Cebu on 6 Mar 1906, the date fixed in the order. The trial court erred in limiting itself to the Executive Order rate; the Supreme Court held that the parties themselves may ascertain the market rate, and the administrator must pay the equivalent amount based on that market price.

5. Disposition of Appeals The Court affirmed the judgment of the CFI, upholding the payment of the ₱30,000 (converted at the proper market rate) with interest, and rejected the administrators’ and heirs’ arguments on both the validity of the will and the alleged condition.

6. Costs No costs were awarded to either party.

7. Remand The case was remanded to the lower court for execution of the now‑final order.

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Key Holding:
– A will duly proved is conclusive as to its execution; a legacy that merely reflects the testator’s desire is not a condition requiring a bond.
– The legatee may claim the legacy with interest from the date of demand, and the conversion to local currency must follow the actual market exchange rate on the date specified by the court.