- Petitioner
- Natividad Batiquin
- Respondent
- Filomena Batiquin
- Citation
- G.R. No. 21164
- Court
- Supreme Court
- Division
- First Division
- Ponente
- Ostrand, J.
- Decided
- March 18, 1924
Summary
This case involved a property partition dispute over seven parcels of land in Danao, Cebu, originally owned by deceased spouses Braulio Gonzales and Dominga Batiquin. Both spouses had made wills naming each other as universal heirs. After both died, collateral heirs from each side claimed rights to the property. The Supreme Court affirmed the trial court's decision favoring the defendants (Braulio's heirs), ruling that Dominga's will was validly executed under Spanish law and that title properly vested in Braulio as her universal heir upon her death. The Court rejected arguments that the will was invalid for lack of proper notarial certification or probate proceedings, noting that probate was not required under Spanish law. The decision established important precedents regarding the validity of pre-American wills and succession rights under Spanish law.