In the Matter of the Estate of Tomas Rodriguez v. Margarita Lopez

Summary

This Supreme Court case resolved a succession dispute over half of Tomas Rodriguez's estate between Margarita Lopez (claiming by intestate succession as nearest relative) and Luz Lopez de Bueno (claiming by accretion as surviving universal heir). The Court applied Civil Code Article 753, ruling that Vicente F. Lopez's share was invalid due to his incapacity as guardian without approved final accounts. Under Article 982 on accretion, when co-heirs are instituted without designated shares and one predeceases or is disqualified, the survivor takes the whole inheritance. The Court held that accretion provisions (Article 982) are more specific than and control over general intestate succession rules (Article 912), rejecting the argument for partial intestacy. The decision affirmed the principle against partial intestacy and established that accidental incapacity to receive inheritance favors accretion over intestate succession.