G.R. No. L-28032 September 24, 1986
FRANCISCA TIOCO DE PAPA, MANUEL TIOCO, NICOLAS TIOCO and JANUARIO PAPA, plaintiffs-appellees, vs. DALISAY TONGKO CAMACHO, PRIMO TONGKO and GODOFREDO CAMACHO, defendants-appellants.

FACTS

The case involves the application of the reserva troncal under Article 891 of the Civil Code. The parties submitted a Stipulation of Facts. The properties in dispute originated from two sources: four parcels donated by Romana Tioco to her niece Toribia Tioco, and three parcels inherited by Toribia from her father Balbino Tioco. Toribia predeceased her father, so these seven parcels passed to her two legitimate children, Faustino Dizon and Trinidad Dizon (mother of defendant Dalisay), in equal shares.
Faustino Dizon died intestate, single, and without issue in 1937. His one-half share passed to his father, Eustacio Dizon, as sole intestate heir, but subject to a reserva troncal because the property was acquired by Faustino by gratuitous title from a relative (Toribia) within the third degree. Eustacio thus held this half-share as a reservista. Trinidad died in 1939, and her half-share passed to her only child, Dalisay. Upon Eustacio’s death in 1965, the dispute arose over his reserved half-share.

ISSUE

The legal issue is whether, upon the death of the reservista (Eustacio Dizon), the reserved property should revert exclusively to the defendant Dalisay (the sole relative within the third degree of the original propositus, Faustino Dizon, who is also a descendant of the line of origin), or whether it should be shared with the plaintiffs (the Tioco siblings), who are also third-degree relatives of Faustino but belong to a collateral line.

RULING

The Supreme Court reversed the lower court and ruled in favor of the defendant Dalisay Tongko-Camacho. The legal logic is anchored on the nature and purpose of reserva troncal. The property subject to reserva does not form part of the reservista’s estate for general succession. Instead, it reverts to the relatives of the propositus (Faustino) who are within the third degree and belong to the line from which the property originally came.
The Court, citing Padura v. Baldovino and Cano v. Director of Lands, held that the right of the reservatario is not a right of succession from the reservista but a reversion to the line of origin by operation of law. The applicable order of preference is determined by the rules of intestate succession as if the propositus (Faustino) had died at the moment of the reservista’s (Eustacio’s) death, but considering only relatives within the third degree from the propositus who are also from the line of origin.
Here, the line of origin is that of Toribia Tioco, the mother who transmitted the property to Faustino. Upon Eustacio’s death, the reserved property must revert to the relatives of Faustino within the third degree belonging to Toribia’s line. Dalisay, as Faustino’s niece (a descendant of his sister Trinidad), is a relative within the third degree and is the closest relative in that line. The plaintiffs, while also third-degree relatives (being uncles and an aunt of Faustino), are collateral relatives from a different branch (Balbino’s line). The property must return to the direct descending line from which it came. Therefore, Dalisay, as the sole reservatario from that direct line, is entitled to the entirety of the reserved property