Institution of Heirs and Preterition in the Philippines

Answer Summary

The institution of heirs is the testamentary act by which a testator designates persons to succeed to his property and transmissible rights and obligations. Preterition—the total omission of a compulsory heir in the direct line from a will, without a valid disinheritance—annuls the entire institution of heirs. Devises and legacies survive unless they impair legitimes; if the will contains no devises or legacies, the entire will is void and intestate succession results. This rule is strictly enforced to protect forced heirs from being tacitly deprived of their legitimes.

The governing provision is Article 854 of the Civil Code, which states: “The preterition or omission of one, some, or all of the compulsory heirs in the direct line, whether living at the time of the execution of the will or born after the death of the testator, shall annul the institution of heir; but the devises and legacies shall be valid insofar as they are not inofficious.” The institution of heirs is governed by Article 840 (designation of successor) and Article 843 (heir must be named or clearly described). The leading Supreme Court decisions are Nuguid v. Nuguid (G.R. No. L-23445, 23 June 1966, J. Sanchez), which declared a will void ab initio (from the beginning) for preterition of ascendants; Acain v. Intermediate Appellate Court (G.R. No. 72706, 27 October 1987), holding that omission of an adopted child annuls the institution; and Trinidad v. Trinidad (G.R. No. 254695, 6 December 2023), which clarified that mere mention without bequest amounts to preterition. Neri v. Akutin (74 Phil. 185, 1941) is the foundational case under the old Civil Code, consistently followed.

Three elements must concur for preterition: (1) the omitted person is a compulsory heir in the direct line (ascendants, descendants, including adopted and illegitimate children); (2) the omission is total—the heir receives nothing under the will, whether as instituted heir, legatee, or devisee; (3) there is no express, valid disinheritance under Articles 915–921. The effect of preterition is to annul the institution of heirs in toto; any devises or legacies remain valid only to the extent they do not impair the legitime of the omitted heir.

The most common error is a testator’s attempt to silently disinherit a compulsory heir by granting the entire estate to others. This is preterition and voids the institution, leading to intestacy (Nuguid, Acain). Another frequent mistake is believing that a general statement that an heir “received his share during his lifetime” suffices; without proof and an express disinheritance, it is preterition (Neri v. Akutin). The distinction between preterition and ineffective disinheritance is critical: preterition annuls the entire institution, while an invalid disinheritance merely annuls the institution “insofar as it may prejudice the person disinherited,” a partial nullity (Nuguid). Further, preterition presupposes that the will contains an institution of an heir; a will that merely disinherits a compulsory heir without instituting anyone is not void for preterition, but must be probated to give effect to the disinheritance (Seangio v. Reyes).

Article 854 has remained unchanged since the Civil Code took effect in 1950. As of 2026, no rulings from 2024–2026 were found on this topic. A leading authority is Trinidad v. Trinidad (2023).

Section I — Issue Overview

1. How are heirs instituted in a will under the Philippine Civil Code? The institution of heirs is the fundamental testamentary act by which the testator designates those who will succeed to his property and obligations. Understanding the statutory requirements is the first step in determining whether a will is validly constituted and how the estate will devolve.

2. What is preterition (omission of a compulsory heir in the direct line) and what is its effect on the institution of heirs and on the validity of the will itself? This question addresses the protective mechanism for compulsory heirs. The answer defines preterition, identifies its requisites, and explains its drastic consequence—annulment of the institution of heirs—and the circumstances under which the entire will collapses into intestacy.

Section II — Legal Analysis

Issue 1: How are heirs instituted in a will under the Philippine Civil Code?

Applicable Laws & Issuances

The Civil Code of the Philippines (Republic Act No. 386) governs testamentary succession. The relevant provisions are found in Book III, Title IV. The full text of the operative articles is available via authoritative web sources.

Article 840 defines the institution of an heir: “Institution of heir is an act by virtue of which a testator designates in his will the person or persons who are to succeed him in his property and transmissible rights and obligations.” (BOOK III (FULL TEXT) : CIVIL CODE OF THE PHILIPPINES)

Article 843 requires certainty of designation: “The heir must be one who is designated by his name and surname, and if there are two persons having the same names, the testator shall indicate some circumstance by which the instituted heir may be known. Even though the testator may have omitted the name of the heir, should he designate him in such a way that there can be no doubt as to who has been instituted, the institution shall be valid.” (Id.)

Thus, the institution may be a universal designation (all property) or a specific designation (a determined share or property). An institution of heirs is distinct from a legacy or devise, which bequeaths specific property by particular title. A will may validly contain an institution of an heir without disposing of the entire estate; the remainder passes to the legal or intestate heirs.

Case Law Analysis

The database cases relevant to this issue primarily provide factual illustrations of how heirs are instituted. They confirm that an institution of an heir may be universal, as in Nuguid v. Nuguid (the testatrix “give, devise, and bequeath all of the property … to my beloved sister Remedios”), or may be by way of naming specific individuals to succeed to the entire estate, as in Acain v. Intermediate Appellate Court (instituting the children of a predeceased brother as universal heirs). In Trinidad v. Trinidad, the testator named all his compulsory heirs but effectively gave nothing to some because the sole property bequeathed did not belong to him; the Court treated this as a defective institution that constituted preterition.

The key lesson from these cases is that an institution of an heir can take many forms, but it must clearly convey the testator’s animus testandi (intention to dispose mortis causa). A will may also validly contain no institution at all; Article 841 provides that “a will shall be valid even though it should not contain an institution of an heir,” in which case testamentary dispositions (like disinheritance or specific legacies) are carried out and the remainder goes by intestacy. This principle was pivotal in Seangio v. Reyes, where the holographic will contained only a disinheritance clause but no affirmative institution of an heir.

Recent Developments

No new statutes or Supreme Court rulings (2024–2026) were identified that alter the rules on institution of heirs. Legal commentary continues to rely on the settled Civil Code provisions and the cases discussed above. (See commentary: Inheritance Rights and Preterition in Philippine Succession Law, July 2025.)

Analysis

The institution of heirs is the core of testamentary succession. As long as the testator clearly designates the successor—by name or by unmistakable description—the institution is valid. The testator is not required to institute all his heirs, nor to distribute the entire estate by will. The institution, however, is always subject to the legitimes of compulsory heirs; an institution that impairs legitimes is not void, but is reducible to the extent of the inofficious portion. A lawyer drafting a will should ensure that the institution clauses precisely identify the intended heir and that the disposition, if universal, accounts for the forced shares.

Issue 2: What is preterition (omission of a compulsory heir in the direct line) and what is its effect on the institution of heirs and on the validity of the will itself?

Applicable Laws & Issuances

Article 854, Civil Code is the exclusive statutory provision on preterition. It reads:

“The preterition or omission of one, some, or all of the compulsory heirs in the direct line, whether living at the time of the execution of the will or born after the death of the testator, shall annul the institution of heir; but the devises and legacies shall be valid insofar as they are not inofficious. If the omitted compulsory heirs should die before the testator, the institution shall be effectual, without prejudice to the right of representation.”

Article 855 provides the order of payment for the legitimes of omitted compulsory heirs: first from the free portion, then pro rata from the shares of other compulsory heirs.

Article 919 lists the exclusive causes for disinheritance; Article 918 states that an imperfect disinheritance (i.e., without legal cause or without express specification) shall annul the institution of heirs only “insofar as it may prejudice the person disinherited.” Preterition, in contrast, produces a total annulment of the institution because the compulsory heir is entirely omitted.

Case Law Analysis

Summary Table

Detailed Case Analysis

1. Nuguid v. Nuguid — 23 June 1966 (J. Sanchez)

Focus of Dispute: Whether a holographic will that instituted the testatrix’s sister as sole universal heir, completely omitting the testatrix’s ascendant parents, was void for preterition under Article 854.

Facts: Rosario Nuguid died single and without descendants, leaving her parents Felix and Paz Nuguid as compulsory heirs in the direct ascending line. Her holographic will stated: “I… do hereby give, devise, and bequeath all of the property which I may have when I die to my beloved sister Remedios Nuguid…” It contained no other disposition, no mention of the parents, and no disinheritance.

Arguments:

• Petitioner (Remedios): The will should be probated; the omission was not preterition but an ineffectual disinheritance.
• Oppositors (parents): The will is void for preterition because they are compulsory heirs who received nothing.

Disposition: The order dismissing the petition for probate was affirmed. The will was a “complete nullity.”

Ratio Decidendi: The Court adopted Manresa’s definition of preterition: the compulsory heir is neither instituted, disinherited, nor given any part of the estate. The Court held:

“Preterition consists in the omission in the testator’s will of the forced heirs or anyone of them, either because they are not mentioned therein, or, though mentioned, they are neither instituted as heirs nor are expressly disinherited.”

The effect: “The one-sentence will here institutes petitioner as the sole, universal heir—nothing more. No specific legacies or bequests are therein provided for. It is in this posture that we say that the nullity is complete. Perforce, Rosario Nuguid died intestate.” Since the will contained only a universal institution, annulment of that institution left nothing—total intestacy.

Evidence Evaluated: The will itself, reproduced in full, showed on its face the total omission of the parents. No extrinsic evidence was necessary.

Precedential Status: This is the leading Supreme Court decision on preterition under the present Civil Code. It remains good law and has been consistently cited, including in Acain, Trinidad, and Morales.

2. Acain v. Intermediate Appellate Court — 27 October 1987

Focus of Dispute: Whether the will of Nemesio Acain, which gave his entire share of the conjugal property to his brother Segundo’s children, preterited his legally adopted daughter and widow, and thus was void.

Facts: The testator was survived by his widow Rosa Diongson and a legally adopted daughter Virginia A. Fernandez. Neither was mentioned or disinherited in the will. The will instituted only the children of his predeceased brother as universal heirs without any legacies or devises.

Disposition: Petition denied; will void as to the institution of heirs, total intestacy.

Ratio Decidendi: The Court held that Virginia, as a legally adopted child, is a compulsory heir in the direct line under Article 39 of P.D. No. 603. Her total omission was preterition. Although Acain applied the then-governing Presidential Decree No. 603, the current adoption law — Republic Act No. 11642 (2022) — likewise deems a legally adopted child a legitimate child of the adopter for all intents and purposes (Section 41), with reciprocal rights of succession between adopter and adoptee (Section 43), so the same preterition rule continues to apply. The widow, though a compulsory heir, is not in the direct line; her omission alone would not constitute preterition but a different remedy (completion of legitime). However, the preterition of the adopted daughter annulled the entire institution, and because there were no devises or legacies, the will was a nullity. The Court stated: “Preterition annuls the institution of an heir and annulment throws open to intestate succession the entire inheritance. … The only provisions which do not result in intestacy are the legacies and devises made in the will.”

Evidence Evaluated: The will on its face omitted the adopted daughter. The fact of adoption was undisputed.

Precedential Status: Reinforces Nuguid and extends its application to adopted children. Still good law.

3. Trinidad v. Trinidad — 6 December 2023

Focus of Dispute: Whether the testator’s will preterited some of his compulsory heirs when the sole property bequeathed to them (a condominium unit) did not belong to him, and whether devises and legacies in favor of other heirs could survive.

Facts: Wenceslao Trinidad’s will named all eight compulsory heirs (his wife and seven children). However, to several children (respondents), he bequeathed only a condo unit registered not in his name but in Monique Toda’s name. They thus received nothing. The will contained devises and legacies in favor of petitioners (the wife and other children).

Disposition: Petition partially granted; the Court of Appeals’ dismissal of probate was modified. The case was remanded to the RTC to proceed with probate, recognizing that the devises and legacies may be valid if not inofficious.

Ratio Decidendi: The Court defined preterition as the omission of a compulsory heir who is “neither instituted as an heir nor assigned any part of the estate without expressly being disinherited—tacitly depriving the heir of his legitime.” It required that the omission be total—the heir received no legacies, devises, or advances. Because the bequeathed property did not belong to the testator, the respondents effectively received nothing, constituting preterition. The institution of heirs was annulled. However, the Court stressed that under Article 854, “the devises and legacies shall be valid insofar as they are not inofficious.” Thus, the will was not completely void; the devises and legacies in favor of petitioners could be respected upon probate, subject to legitime protection. The Court distinguished universal institution (bequest of undetermined property) from legacy (specific property). Because the will contained devises/legacies, total intestacy was not automatic.

Evidence Evaluated: Petitioners failed to prove ownership of the condo unit. Checks, keys, and membership cards were insufficient. The will’s terms showed the testator bequeathed a property he did not own.

Precedential Status: The most recent Supreme Court pronouncement (2023), refining the effect of preterition when devises/legacies are present. It will guide future probate courts.

4. Neri v. Akutin — 13 June 1941

Focus of Dispute: Whether the omission of children from the first marriage constituted preterition or merely an ineffective disinheritance.

Facts: Agripino Neri’s will granted his entire estate to his children by the second marriage, stating that the children of the first marriage “shall have no longer any participation in his estate, as they had already received their corresponding shares during his lifetime.” The trial court found this statement false—most first-marriage children received nothing. One daughter predeceased him, and her seven children were also omitted.

Disposition: Reversed; institution void, intestate succession.

Ratio Decidendi: The Court held that preterition “consists in the omission in the testator’s will of the forced heirs or anyone of them, either because they are not mentioned therein, or though mentioned, they are neither instituted as heirs nor are expressly disinherited.” The testator’s statement negated any intent to disinherit; it was a mere mistake of fact. Thus, it was not an ineffectual disinheritance under Article 851 of the Spanish Civil Code (now Article 918) but preterition under Article 814 (now Article 854). The effect was to void the institution and cause intestacy, because the will contained no express legacies or “betterments” (mejoras). The Court explained: “except as to ‘legacies and betterments’ which ‘shall be valid in so far as they are not inofficious’ … preterition avoids the institution of heirs and gives rise to intestate succession.”

Evidence Evaluated: The trial court’s finding of fact that the first-marriage children had received no advancement was crucial; it rebutted the testator’s declared assumption.

Precedential Status: Decided under the old Spanish Civil Code, but the provision is substantively identical to Article 854. It remains the foundational case on the definition of preterition and is routinely cited, including in Nuguid.

5. Ventura v. Ventura — 27 May 1977

Focus of Dispute: Whether the institution of heirs in a probated will could be annulled due to preterition of legitimate daughters whose legitimacy was established post-probate.

Facts: Gregorio Ventura’s will was probated during his lifetime. After his death, Mercedes and Gregoria Ventura filed a motion asserting they were legitimate compulsory heirs omitted from the will. A separate civil case declared them legitimate. The trial court applied Article 854 and annulled the institution of heirs, preserving devises and legacies if not inofficious. The executrix appealed, but the legitimacy decision became final and executory.

Disposition: Appeal dismissed as moot; the annulment of the institution stood.

Ratio Decidendi: The Supreme Court did not re-examine the merits because the legitimacy judgment conclusively established they were compulsory heirs. The annulment of the institution and the saving of devises/legacies directly followed Article 854, confirming that preterition annuls the institution but may leave specific bequests intact.

Evidence Evaluated: The final and executory judgment in Civil Cases Nos. 1064 and 1476 was decisive.

Precedential Status: Illustrates that preterition can be raised even after probate, once the status of compulsory heir is judicially confirmed.

6. Seangio v. Reyes — 27 November 2006

Focus of Dispute: Whether a holographic will that disinherited one compulsory heir but did not institute any heir was void for preterition.

Facts: Segundo Seangio’s holographic document, entitled “Kasulatan sa Pag-Aalis ng Mana” (Deed of Disinheritance), disinherited his eldest son Alfredo for specified legal causes, but named no other heir or devisee. The surviving spouse and other children were not mentioned. The trial court dismissed probate on the ground of preterition, relying on Acain. The Supreme Court reversed.

Disposition: Granted; case remanded for probate.

Ratio Decidendi: The Court held that preterition under Article 854 “annuls the institution of an heir.” Where no heir was instituted, there is nothing to annul. The will’s sole testamentary act—a valid disinheritance—is a disposition that must be probated. The Court stated: “The mere mention of the name of one of the petitioners, Virginia, in the document did not operate to institute her as the universal heir.” Citing Article 841, a will is valid even without an institution of an heir. Thus, the absence of an institution does not result in preterition. The other compulsory heirs were not preterited because they were not entitled to any share under a will that merely disinherited one heir; upon probate, the disinherited heir’s share would go to his own descendants or be distributed by intestacy among the other compulsory heirs.

Evidence Evaluated: The will itself showed only a disinheritance; no institution was found. The trial court had misapplied Acain, which involved a clear institution of universal heirs.

Precedential Status: This ruling draws a critical line: preterition requires an institution to annul. A pure disinheritance will is not void for preterition. Good law and cited in subsequent commentaries.

7. Morales v. Olondriz — 3 February 2016

Focus of Dispute: Whether an illegitimate son, a compulsory heir in the direct line, was preterited when the will divided the entire estate among other children and the widow without providing for him.

Facts: The decedent’s will divided his entire estate equally among six named individuals (executor, four children, and their mother), omitting Francisco Javier Maria Bautista Olondriz, the testator’s admitted illegitimate son. The will contained no devises or legacies.

Disposition: Petition dismissed; the trial court’s order to proceed with intestacy was affirmed.

Ratio Decidendi: The Court reiterated the definition of preterition: “Preterition requires that the omission is total, meaning the heir did not also receive any legacies, devises, or advances on his legitime.” Because the illegitimate son was a compulsory heir in the direct line (Article 887), and the will gave him nothing, preterition occurred. The annulment of the institution resulted in total intestacy because the will contained no devises or legacies. The Court held: “The decedent’s will, no matter how valid it may appear extrinsically, is null and void.”

Evidence Evaluated: The will on its face omitted the illegitimate son. Petitioner Morales claimed the son had received a house and lot inter vivos as an advance, but she waived her right to present evidence, failing to prove any inter vivos donation that could cure the omission.

Precedential Status: Confirms that an illegitimate child is a compulsory heir whose total omission constitutes preterition, and that failure to prove inter vivos advances results in intestacy. Good law.

Doctrinal Synthesis

The current legal position is well-settled:

1. Preterition is a total omission. A compulsory heir in the direct line must receive nothing under the will—no institution, no legacy, no devise, no acknowledgment of an advance on the legitime. If the heir receives even a token legacy, preterition does not occur; the remedy is an action for completion of legitime under Article 906. (See Trinidad; Morales; Preterition | Compulsory Succession.)

2. Preterition annuls the institution of heirs in its entirety. This is a drastic, automatic consequence. It does not matter whether the testator acted intentionally or inadvertently; even a well-meaning testator who mistakenly believes an heir has already received his share commits preterition (Neri). The nullity is not partial; it sweeps the entire institution away (Nuguid; Acain).

3. Devises and legacies survive preterition unless inofficious. Article 854 expressly preserves specific bequests. Thus, if a will contains both an institution of heirs and specific devises/legacies, the institution is annulled but the specific bequests remain effective, provided they do not impair the legitime of the preterited heir (Trinidad; Ventura). If the will consists solely of a universal institution without any devises/legacies, preterition results in total intestacy (Nuguid; Acain; Morales).

4. Preterition is distinct from ineffective disinheritance. Disinheritance must be express, for a cause recognized by law (Article 919), and stated specifically in the will. A failed disinheritance merely annuls the institution “insofar as it may prejudice the person disinherited,” leaving the rest of the will intact. Preterition, by contrast, annuls the entire institution. The testator’s mere statement that an heir “has already received his share” or that the heir “should not participate” is not a valid disinheritance and constitutes preterition (Neri; Nuguid).

5. Preterition presupposes an institution of an heir. A will that merely disinherits a compulsory heir without instituting any other heir does not produce preterition. The disinheritance, if valid, stands; the will must be probated, and the estate not covered by the disinheritance passes by intestacy. This is the rule of Seangio v. Reyes, which practitioners must carefully note when evaluating a will that contains only a disinheritance clause.

Practical guidance for lawyers:

• When drafting a will, always identify all compulsory heirs in the direct line. Provide for them by name, either by: (a) instituting them as heirs to the extent of their legitimes; (b) giving them legacies or devises; or (c) expressly disinheriting them for a lawful cause with the specific cause stated. If the testator wishes to favor one child, the will must respect the legitimes of the others or validly disinherit them.
• When challenging a will for preterition, the challenger must prove: (a) his status as a compulsory heir in the direct line; (b) total omission from the will (no mention as heir, legatee, or devisee); and (c) absence of a valid disinheritance. Documentary evidence is paramount—the will itself, birth certificates, adoption decrees, or judicial declarations of filiation.
• If the will contains both an institution and devises/legacies, and an heir is preterited, the executor must preserve the devises/legacies and distribute the remainder by intestacy, ensuring the preterited heir’s legitime is satisfied first.

Recent Developments

No new Supreme Court decisions on preterition were identified from 2024 through July 2026. The most recent ruling remains Trinidad v. Trinidad (2023). Legal commentary from 2024–2025, such as the Respicio article (Preterition | Compulsory Succession), continues to summarize the same principles without indicating any new doctrinal shift. Practitioners may confidently rely on the established precedent.

Analysis

Applying the rules to a typical scenario: if a testator’s will names only one child as universal heir and says nothing about the other compulsory children, those omitted children are preterited. The institution of the universal heir is annulled. If the will contains no other dispositions (no legacies, no devises), the entire will is void. The estate devolves by intestacy among all compulsory heirs. If the same will also leaves a specific condo unit to a grandchild as a legacy, that legacy survives preterition, provided it does not exceed the free portion after satisfying the legitimes of all compulsory heirs, including the omitted child.

The distinction in Seangio is critical: if the testator’s sole testamentary act is a valid disinheritance of a son, the will is not void for preterition of the other children. It must be probated; the disinherited son’s share passes to his own descendants or accretes to the other compulsory heirs. The lesson for drafters is to never rely on silence; always make an affirmative provision or a lawful disinheritance.

Section III — Action Plan & Evidence Guide

Recommended Strategy: For an attorney advising a client who wishes to make a will, the preterition rules must be central to the estate plan. The client must be informed that all compulsory heirs in the direct line must be provided for or validly disinherited; otherwise, the will’s core institution is at risk of total nullity. For an attorney representing an omitted heir, the primary remedy is a petition to annul the institution of heirs in the testate proceeding or a separate action, ideally before probate is finalized. Time is of the essence: the action to claim a legitime or annul an institution based on preterition prescribes in four years from the date of distribution or knowledge of the preterition (Article 1144, by analogy).

Action Steps:

1. Drafting a will to avoid preterition — Identify all compulsory heirs in the direct line (legitimate, adopted, and illegitimate children; parents if no descendants). Decide whether each will receive a share as instituted heir, a specific legacy/devise, or be disinherited. If disinheriting, draft the clause in strict compliance with Articles 915–919, specifying the exact legal cause. Never assume a lifetime donation cures the omission unless it is proven and declared as an advance on legitime; otherwise, it may be disregarded.

2. Challenging a will for preterition — Secure official copies of the will from the probate court. Obtain documents establishing the client’s filiation (birth certificate, adoption decree, judicial declaration of legitimacy/illegitimacy). Gather evidence that the client received nothing under the will—no institution, no legacy, no devise. If an inter vivos donation is alleged by the proponent, prepare to rebut it with evidence that no such donation was made or that it was not an advance on legitime.

3. Probate strategy when preterition is alleged — If the will contains devises/legacies in addition to the institution, emphasize that Article 854 preserves them and urge the court not to dismiss probate outright but to allow the will and preserve the specific bequests, as ordered in Trinidad v. Trinidad. If the will is a pure disinheritance document, rely on Seangio v. Reyes to argue that preterition has no application and the will must be probated.

Evidence Checklist:

• Certified true copy of the last will and testament — proves the dispositive provisions, the absence of mention of the omitted heir, and lack of devises/legacies.
• Certificate of Death of the testator — establishes date of death and opens succession.
• Birth certificate / adoption decree / court decision on filiation of the omitted heir — proves status as compulsory heir in the direct line.
• Marriage certificate of the testator (if surviving spouse is also omitted and to establish the property regime) — although spouse is not in the direct line, may support a claim for legitime.
• Inventory of the estate — needed to compute legitimes and determine if devises/legacies are inofficious.
• Evidence of any inter vivos donations (deeds, receipts, tax returns) — may be offered by the proponent to argue the omission is not total; must be proven to be advances on legitime.

⚠️ This is AI-generated legal research for reference only. It does not constitute legal advice. Consult a licensed Philippine attorney before making important legal decisions.

References

Legislation & Regulatory Issuances

• Civil Code of the Philippines (Republic Act No. 386)
• BOOK III (FULL TEXT) : CIVIL CODE OF THE PHILIPPINES — chanrobles.com

Case Law

• REMEDIOS NUGUID, petitioner-appellant, vs. FELIX NUGUID and PAZ SALONGA NUGUID, oppositors-appellees, G.R. No. L-23445 — Nuguid v. Nuguid (23 June 1966)
• CONSTANTINO C. ACAIN, petitioner, vs. HON. INTERMEDIATE APPELLATE COURT (Third Special Cases Division), VIRGINIA A. FERNANDEZ and ROSA DIONGSON, respondents, G.R. No. 72706 (27 October 1987)
• NELFA DELFIN TRINIDAD, JON WILFRED D. TRINIDAD and TIMOTHY MARK D. TRINIDAD, petitioners, vs. SALVADOR G. TRINIDAD, WENCESLAO ROY G. TRINIDAD, ANNA MARIA NATIVIDAD G. TRINIDAD-KUMP, GREGORIO G. TRINIDAD and PATRICIA MARIA G. TRINIDAD, respondents, G.R. No. 254695 (6 December 2023)
• Administration of the estate of Agripino Neri y Chavez. ELEUTERIO NERI, ET AL., petitioners, vs. IGNACIA AKUTIN AND HER CHILDREN, respondents, G.R. No. 47799 (13 June 1941)
• TESTATE ESTATE OF THE LATE GREGORIO VENTURA: MARIA VENTURA, executrix-appellant, MIGUEL VENTURA and JUANA CARDOVA, Heirs, vs. MERCEDES VENTURA, and her husband PEDRO D. CORPUZ, and GREGORIA VENTURA and her husband EXEQUIEL VICTORIO, oppositors-appellees, G.R. No. L-23875 (27 May 1977)
• DY YIENG SEANGIO, BARBARA D. SEANGIO and VIRGINIA D. SEANGIO, petitioners, vs. HON. AMOR A. REYES, in her capacity as Presiding Judge, Regional Trial Court, National Capital Judicial Region, Branch 21, Manila, ALFREDO D. SEANGIO, ALBERTO D. SEANGIO, ELISA D. SEANGIO-SANTOS, VICTOR D. SEANGIO, ALFONSO D. SEANGIO, SHIRLEY D. SEANGIO-LIM, BETTY D. SEANGIO-OBAS and JAMES D. SEANGIO, respondents, G.R. Nos. 140371-72 (27 November 2006)
• IRIS MORALES, petitioner, vs. ANA MARIA OLONDRIZ, ALFONSO JUAN OLONDRIZ, JR., ALEJANDRO MORENO OLONDRIZ, ISABEL ROSA OLONDRIZ and FRANCISCO JAVIER MARIA OLONDRIZ, respondents, G.R. No. 198994 (3 February 2016)