Intestate of the Deceased Encarnacion Saenz de Vizmano Miguel Velasco y Cuarteroni v. Remedios Vismanos

Summary

This case involves an intestate succession dispute where Encarnacion Saenz de Vizmanos died without forced heirs in 1921. The Court of First Instance appointed an administrator and declared fourth-degree collateral relatives as heirs, excluding sixth-degree relatives (appellants) from inheritance. The appellants challenged this on grounds that the declared heirs were not properly represented, arguing the court lacked jurisdiction. The Supreme Court affirmed the distribution order, ruling that inheritance title transmits immediately upon death under Civil Code articles 657, 658, and 661, and courts have the duty to distribute to proven heirs regardless of their formal appearance in proceedings. The case establishes that nearer relatives in degree exclude more distant ones in intestate succession, and proper representation is not required for heirs to inherit under Philippine succession law.