Petitioner
Rosales
Respondent
Rosales
Citation
G.R. No. L-40789
Court
Supreme Court
Division
First Division
Ponente
Gancayco, J.
Decided
February 27, 1987

Summary

This case involved a dispute over inheritance rights in the intestate estate of Petra V. Rosales. The deceased's daughter-in-law, Irenea C. Rosales, whose husband predeceased his mother, claimed a share of the estate as a compulsory heir. The Court of First Instance excluded her from inheritance, recognizing only the husband, children, and grandson (by right of representation) as legal heirs. The Supreme Court affirmed, holding that a surviving spouse is not an intestate heir of her parent-in-law under the Civil Code. The Court emphasized that intestate succession follows specific provisions, and no law grants daughters-in-law inheritance rights from mothers-in-law. The decision clarified that surviving spouses are third persons regarding their parent-in-law's estates, and only blood relatives can inherit by right of representation.

Intellegal Wiki · Key Holding

A surviving spouse is not an intestate heir of a parent-in-law; intestate heirs succeed either by their own right or by the right of representation (Article 981), and a daughter-in-law has no such right to inherit from her mother-in-law.

An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.

Related cases

Other Philippine cases on the same provisions and issues.

Featured in research

In-depth Intellegal research that discusses this case.

Common questions

Plain-language Q&A on the issues in this case.

Search Philippine case law on Intellegal →

By the Intellegal Editorial Board · February 27, 1987

Search Philippine case law on Intellegal →
AI-assisted case analysis — for research only. Verify against the official decision. A research aid, not legal advice; using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer. Verify every holding and citation against the official decision (Supreme Court E-Library / Official Gazette) before relying on it.