GR L 13386; (October, 1920) (Digest)
G.R. No. L-13386; October 27, 1920
SEGUNDA MARIA NIEVA and ANGEL ALCALA, plaintiffs-appellants, vs. MANUELA ALCALA and JOSE DEOCAMPO, defendants-appellees.
FACTS:
Juliana Nieva, the unmarried natural mother of plaintiff Segunda Maria Nieva, later married Francisco Deocampo. Their legitimate son was Alfeo Deocampo. Juliana Nieva died intestate in 1889, and Alfeo inherited from her certain parcels of land. Alfeo died intestate and without issue in 1890, and the property passed by operation of law to his father, Francisco Deocampo. Francisco later married defendant Manuela Alcala, and their son was defendant Jose Deocampo. Upon Francisco’s death in 1914, the defendants took possession of the land, claiming Jose inherited it from his father. Segunda Maria Nieva, claiming to be an acknowledged natural daughter of Juliana Nieva, filed an action to recover the land, invoking the right of reserva troncal under Article 811 of the Civil Code. The lower court absolved the defendants, ruling that an illegitimate relative has no right to the reserva troncal.
ISSUE:
Whether an illegitimate relative within the third degree is entitled to the reserva troncal provided for under Article 811 of the Civil Code.
RULING:
No. The Supreme Court affirmed the lower court’s judgment. The Court first found that the plaintiff was indeed an acknowledged natural daughter of Juliana Nieva based on uncontroverted facts analogous to prior jurisprudence. On the principal issue, the Court held that the reserva troncal under Article 811 applies exclusively to legitimate relatives. The Court, adopting the reasoning of eminent commentators like Manresa, emphasized that the Civil Code, when referring to “ascendant,” “descendant,” or “relatives” in a general sense without qualification, intends only legitimate relatives. Provisions concerning natural relatives are specifically designated as such. Article 811 is located within the part of the Code dealing with the legitime of legitimate ascendants. Furthermore, the underlying principle of reserva troncal is to preserve property within the legitimate family line. To extend it to illegitimate relatives would violate Article 943, which prohibits intestate succession between legitimate and natural families. Therefore, the plaintiff, as an illegitimate sister, had no right to the reserved property, which rightfully passed to the legitimate descendant, the defendant Jose Deocampo.