Heirs of Rosendo Lasam v. Vicenta Umengan

Summary

This case involves an unlawful detainer action filed by heirs of Rosendo Lasam against Vicenta Umengan over possession of real property in Tuguegarao City. The MTCC and RTC initially ruled for petitioners based on Isabel Cuntapay's purported last will and testament bequeathing the lot to Rosendo Lasam. However, the Court of Appeals and Supreme Court reversed, finding that the unprobated will violated formal requirements and had no legal effect under Article 838 of the Civil Code. The Supreme Court held that respondent had better right to possession through valid conveyances from Isabel's other children and prior possession since 1955. The decision clarifies that unprobated wills cannot establish rights and that heirs may validly dispose of their pro indiviso shares in inherited property.