Oscar Constantino v. Heirs of Pedro Constantino, Jr.

Summary

This inheritance dispute involved heirs of Pedro Constantino Sr. challenging the validity of extrajudicial settlements that excluded certain heirs from their rightful shares in the estate. Petitioners executed a 'Pagmamana sa Labas ng Hukuman' in 1992 claiming an entire 240 sq.m. property, while respondents had earlier executed an 'Extrajudicial Settlement with Waiver' in 1968 covering a 192 sq.m. lot. The trial court applied the pari delicto doctrine finding both parties equally at fault, while the Court of Appeals distinguished the properties involved. The Supreme Court ultimately declared both settlements void for violating legitime laws by excluding rightful heirs, ruling that the pari delicto doctrine was inapplicable as it would legitimize illegal agreements that circumvent mandatory inheritance laws. The decision reinforces the principle that extrajudicial settlements must include all heirs to be valid and that circumvention of legitime laws cannot be countenanced.