Cabuyao v. Caagbay

Summary

This landmark succession case established that an alleged heir can maintain an action to recover inherited property without prior judicial declaration of heirship. Damaso Cabuyao, claiming to be the sole heir of his deceased parents, sued relatives who occupied family lands after his mother's death in 1944. The trial court dismissed his case, ruling he needed judicial declaration of heirship first. The Supreme Court reversed, holding that under Rule 74 of the Rules of Court, a sole heir can adjudicate an estate extrajudicially by affidavit if no debts exist and heirs are of age. Citing Civil Code provisions that succession rights transmit upon death, the Court established the principle that heirs succeed by operation of law without need for prior judicial declaration, affirming their standing to assert inheritance rights directly.