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Republic of The Philippines Vs David Rey Guzman

Helen, an American citizen, executed two quitclaim deeds transferring her interest in land she inherited from her late husband Simeon to their son David, also an American citizen. However, Helen had already accepted her inheritance in a 1970 deed dividing Simeon's estate between her and David. Under Philippine law, the acceptance of an inheritance cannot later be revoked unless due to causes invalidating consent or an unknown will. As there was no evidence of this, Helen's quitclaim deeds had no legal force and the land remained under her ownership despite her American citizenship, which did not prohibit hereditary succession to private property.

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88 views2 pages

Republic of The Philippines Vs David Rey Guzman

Helen, an American citizen, executed two quitclaim deeds transferring her interest in land she inherited from her late husband Simeon to their son David, also an American citizen. However, Helen had already accepted her inheritance in a 1970 deed dividing Simeon's estate between her and David. Under Philippine law, the acceptance of an inheritance cannot later be revoked unless due to causes invalidating consent or an unknown will. As there was no evidence of this, Helen's quitclaim deeds had no legal force and the land remained under her ownership despite her American citizenship, which did not prohibit hereditary succession to private property.

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girl
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REPUBLIC OF THE PHILIPPINES vs DAVID REY GUZMAN

G.R. No. 132964; February 18, 2000


BELLOSILLO, J.:

FACTS:
David Rey Guzman, a natural-born American citizen, is the son of the
spouses Simeon Guzman, a naturalized American citizen, died in 1968
survived by his spouse Helen, an American citizen, and his son David
Rey leaving properties located in Bulacan. On December 29, 1970,
the heirs executed a Deed of Extrajudicial Settlement of his estate.
On December 10 1981 and in August 9, 1989 Helen executed a
Quitclaim Deed assigning, transferring and conveying to her son
David her interest on all the parcels of land subject matter of the
Deed of Extrajudicial Settlement of the Estate of Simeon Guzman in
the Philippines.

On 18 October 1989 David executed a Special Power of Attorney


where he acknowledged ownership over the parcels of land under the
Quitclaim of Helen by executing a Special Power of Attorney and
empowered Atty. Lolita G. Abela to sell or otherwise dispose of the
lots. Later, the Office of the Solicitor General, based on a letter it
received from Atty. Batongbacal which informed them of a defect in
David‘s ownership, filed a Petition for Escheat against David Rey with
prayer that the subject parcels of land be forfeited in favor of the
government.

ISSUE:
Whether or not Helen validly repudiated her interest on the subject
parcels of land.

RULING:
No, the repudiation is not valid because Helen has already accepted
her share of the inheritance when she executed executed a Deed of
Extrajudicial Settlement of the Estate of Simeon Guzman on
December 29, 1970, which divided and adjudicated between Helen
and David the two (2) of them all the property in Simeon's estate. By
virtue of such extrajudicial settlement the parcels of land were
registered in her and her son's name in undivided equal share and for
eleven (11) years they possessed the lands in the concept of owner.
As the Article 1056 of the Civil Code provides, the acceptance or
repudiation of an inheritance, once made is irrevocable and cannot
be impugned, except when it was made through any of the causes
that vitiate consent or when an unknown will appears. Nothing on
record shows that Helen's acceptance of her inheritance from Simeon
was made through any of the causes which vitiated her consent nor
is there any proof of the existence of an unknown will executed by
Simeon. Thus, pursuant to Art. 1056, Helen cannot belatedly execute
an instrument which has the effect of revoking or impugning her
previous acceptance of her one-half (1/2) share of the subject
property from Simeon's estate.
The two (2) quitclaim deeds which she executed eleven (11) years
after she had accepted the inheritance have no legal force and effect.
Nevertheless, the nullity of the repudiation does not ipso facto
operate to convert the parcels of land into res nullius to be escheated
in favor of the Government. The repudiation being of no effect
whatsoever the parcels of land should revert to their private owner,
Helen, who, although being an American citizen, is qualified by
hereditary succession to own the property subject of the litigation.

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