Teotico vs. Del Val

VICENTE TEOTICO vs. ANA DEL VAL, ETC.
GR No. L-18753 | March 26, 1965 | J. Bautista Angelo (Mikee)

Facts:
Maria Mortera y Balsalobre Vda. De Aguirre died on July 14, 1955, leaving a duly executed will. In said will she declared
that she was physically and mentally capable of executing a will, and that she did so with free will. One of the legacies and
devises in said will was of P20,000 to Rene Teotico, husband of the testatrixs niece Josefina Mortera. To said spouses
she left the usufruct of her interest in the Calvo building, while the naked ownership pertained to her grandchildren
(legitimate children of the spouses). Mortera was also instituted as the testatrixs sole and universal heir.
P Vicente Teotico (child of the spouses? wasnt mentioned) filed a petition for probate of the will. R Ana Del Val Chan,
claiming to be an adopted child of Francisca Mortera, a deceased sister of the testatrix AND to be an acknowledged
natural child of Jose Mortera, a deceased brother of the testatrix, filed an opposition to the probate of the will: 1) not
executed according to law; 2) testatrix was physically and mentally incapable of executing such will; and 3) executed
under duress. It was later amended to include the allegation that the will was inoperative as to the share of Dr. Rene
Teotico who was the physician of the testatrix.
P Teotico filed a MtD the opposition, alleging the oppositor had no legal personality to intervene.
Probate court: allowed the intervention of R as an adopted child of Francisca; later admitted the will the probate except for
the disposition to Rene Teotico the said portion shall then pass to the testatrixs heirs thru intestate succession
Relevant issue: WON R has the right to intervene NO
Ratio:
For a person to be allowed to intervene in a probate proceeding, he must have an interest in the estate, in the will, or in
the property to be affected by it either as executor or as a claimant of the estate. An interested party is defined as one
who would be benefited by the estate, such as an heir, or one who has a claim against the estate, such as a creditor. The
interest must be material and direct, and not merely indirect or contingent.
Under the terms of the will, R has no right to intervene because she has no interest in the estate either as heir, executor,
or administrator, nor does she have any claim to any property affected by the will, because it nowhere appears therein any
provision designating her as heir, legatee or devisee of any portion of the estate. She has also no interest in the will either
as administratrix or executrix. Neither has she any claim against any portion of the estate because she is not a co-owner
thereof, and while she previously had an interest in the Calvo building located in Escolta, she had already disposed of it
long before the execution of the will.
Supposing that the will is denied probate, R still has no interest in the portion of the estate left by the testatrix. She would
acquire such right only if she were a legal heir of the deceased, but she is not under our Civil Code. It is true that R claims
to be an acknowledged natural child of Jose Mortera, a deceased brother of the deceased, and also an adopted daughter
of Francisca Mortera, a deceased sister of the testatrix, but such claim cannot give her any comfort for, even if it be true,
the law does not give her any right to succeed to the estate of the deceased sister of both Jose Mortera and
Francisca Mortera. And this is so because being an illegitimate child she is prohibited by law from succeeding to
the legitimate relatives of her natural father.
Article 992 of our Civil Code provides: "An illegitimate child has no right to inherit ab intestato from the legitimate children
and relatives of his father or mother
The philosophy behind this can be found in Grey vs. Fable:
Between the natural child and the legitimate relatives of the father or mother who acknowledged it, the Code denies any
right of succession. They cannot be called relatives and they have no right to inherit. Of course, there is a blood tie, but
the law does not recognize it The natural child is disgracefully looked down upon by the legitimate family; the legitimate
family is, in turn, hated by the natural child; the latter considers the privileged condition of the former and the resources of
which it is thereby deprived; the former, in turn, sees in the natural child nothing but the product of sin, a palpable
evidence of a blemish upon the family. Every relation is ordinarily broken in life; the law does no more than recognize this
truth, by avoiding further grounds of resentment.
R cannot also derive comfort from the fact that she is an adopted child of Francisca Mortera because under our law
the relationship established by adoption is limited solely to the adopter and the adopted and does not extend to the
relatives of the adopting parents or of the adopted child except only as expressly provided for by law. Hence, no
relationship is created between the adopted and the collaterals of the adopting parents. As a consequence, the
adopted is an heir of the adopter but not of the relatives of the adopter.
It thus appears R has no right to intervene either as testamentary or as legal heir in the probate.
As for the other issues, it hasnt been successively proved that the will wasnt duly executed according to law; the claim
that it was procured thru improper pressure and influence isnt well-founded as well. Hence, the will is valid and must be
allowed probate. The probate court also shouldnt have looked into the intrinsic validity of the will the fact that Rene
Teotico was the physician of the testatrix during her last illness particularly because probate is, as a general rule, limited
to the extrinsic validity of a will.
WHEREFORE, with the exception of that portion of the decision which declares that the will in question has been duly
executed and admitted the same to probate, the rest of the decision is hereby set aside. The declaration of the probate
court re: invalidity of the disposition to Rene Teotico must be set aside.

Teotico vs. Del Val

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Teotico vs. Del Val

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VICENTE TEOTICO vs. ANA DEL VAL, ETC.

GR No. L-18753 | March 26, 1965 | J. Bautista Angelo (Mikee)

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