Francisco v. Francisco-Alfonso

Summary

This case involves a succession dispute where legitimate daughter Aida Francisco-Alfonso challenged a 1983 deed of sale transferring her deceased father's two properties to his illegitimate daughters Regina Francisco and Zenaida Pascual. The trial court initially upheld the sale's validity, but the Court of Appeals reversed, finding the contract simulated due to lack of consideration - the petitioners could not credibly explain having P25,000.00 in 1983 given their limited income sources. The Supreme Court affirmed, holding the sale was both simulated and violated Civil Code provisions on legitime, as it deprived the legitimate daughter of her rightful inheritance share. The Court emphasized that compulsory heirs cannot be deprived of their legitime except through legal disinheritance procedures. The decision protects the succession rights of legitimate children against attempts to circumvent inheritance laws through simulated transactions.