Maria Mendoza v. Julia Policarpio Delos Santos

Summary

The Supreme Court denied petitioners' claim over three parcels of land under the reserva troncal doctrine. Petitioners, who are grandchildren of Placido and Dominga Mendoza, sought to recover properties inherited by Gregoria Mendoza from her father Exequiel, and later acquired by Julia Policarpio Delos Santos upon Gregoria's death. The Court ruled that Article 891 of the Civil Code on reserva troncal is inapplicable because Julia is not Gregoria's ascendant but a collateral relative, and petitioners are fourth-degree relatives (first cousins) of Gregoria, beyond the third-degree requirement for reservees. The decision clarifies that the lineal character of reservable property is reckoned from the immediate ascendant who transmitted the property by gratuitous title, not from more remote ancestors. The Court emphasized that reserva troncal grants a personal right only to relatives within the third degree, and representation cannot extend to fourth-degree relatives.