Intestado De La Finada Leoncia Filomena Jardin. Andres Jardin Y Otro, Solicitantes-Apelantes, Contra Severina Villamayor, Opositora-Apelada

Summary

This inheritance case involved the estate of 10-year-old Leoncia Filomena Jardin who died in 1925. Her relatives Andres Jardin (uncle, 5th degree) and Canuto Jardin (great-uncle, 4th degree) sought judicial administration claiming rights to reservable property under Civil Code Article 811. The mother Severina Villamayor opposed, claiming absolute ownership. The Supreme Court affirmed the lower court's dismissal, ruling that the property ceased to be reservable because no relatives within the required third degree of consanguinity survived the deceased. Under Article 811, reservable property must benefit relatives within the third degree from the line of origin, but both petitioners exceeded this degree. The Court recognized Severina Villamayor as the rightful owner through legitimate succession as forced heir under Article 807(2) of the Civil Code.