The Supreme Court clarified the application of reserva troncal under Article 891 of the Civil Code, emphasizing that this special rule ensures property returns to relatives within the third degree of the family line from which it originated. The Court held that the person obliged to reserve the property (the reservista) must be an ascendant of the descendant (prepositus) from whom the property is inherited. Moreover, the relatives who can benefit from this reservation (reservatarios) are strictly limited to those within the third degree of consanguinity from the prepositus, thereby preventing distant relatives from claiming rights to the reserved property. This ruling reinforces the intent of reserva troncal to keep property within the specific family line from which it came, preventing its dispersal to unintended heirs.

Unraveling Family Lines: Who Gets the Inheritance When Kinship Ties Knot

In Maria Mendoza v. Julia Policarpio Delos Santos, the core legal question revolved around the application of reserva troncal concerning several parcels of land in Bulacan. The petitioners, grandchildren of Placido and Dominga Mendoza, claimed that these properties, initially part of Placido and Dominga’s estate, should revert to them after Gregoria, a descendant in their paternal line, died intestate and without issue. The respondent, Julia Policarpio Delos Santos, Gregoria’s aunt, had adjudicated the properties to herself as Gregoria’s sole surviving heir. The petitioners argued that Julia should have reserved these properties for their benefit, invoking Article 891 of the Civil Code, which governs reserva troncal. The case hinged on whether the properties were indeed reservable and whether the petitioners were entitled to the benefits of such reservation.

The principle of reserva troncal, as enshrined in Article 891 of the Civil Code, is designed to ensure that property passes within a specific family line. This article states:

Art. 891. The ascendant who inherits from his descendant any property which the latter may have acquired by gratuitous title from another ascendant, or a brother or sister, is obliged to reserve such property as he may have acquired by operation of law for the benefit of relatives who are within the third degree and belong to the line from which said property came.

This provision establishes a system with three distinct stages of transmission. The initial transfer occurs when an ascendant, brother, or sister gratuitously transfers property to a descendant, known as the prepositus. The second transmission happens by operation of law from the prepositus to another ascendant, the reservista. Finally, the third transmission is from the reservista to the reservatarios, who must be relatives within the third degree from whom the property originally came.

In analyzing the case, the Supreme Court found that the Court of Appeals (CA) had erred in assuming that Placido Mendoza was the ascendant from whom the properties should be traced. Instead, the Court clarified that the origin of the properties should be reckoned from Exequiel, Gregoria’s father, as he was the ascendant from whom Gregoria inherited the properties. The Court emphasized that the law does not extend beyond this immediate ascendant in determining the lineal character of the property. It was deemed immaterial whether Exequiel predeceased Placido and Dominga, or whether Gregoria predeceased Exequiel. What mattered was that Exequiel owned the properties and Gregoria received them by inheritance, a gratuitous title.

The Court also addressed the relationship between Julia and Gregoria, noting that Julia was not Gregoria’s ascendant but rather a collateral relative. Article 964 of the Civil Code defines a collateral line as comprising individuals who are not ascendants or descendants but share a common ancestor. Julia, being Gregoria’s aunt, falls within this category. The Court explained that, in determining collateral relationships, one must ascend to the common ancestor and then descend to the relative in question. In Julia’s case, the ascent is from Gregoria to her mother Leonor (one degree), then to their common ancestors (Leonor and Julia’s parents, totaling two degrees), and finally, the descent to Julia (three degrees), making her a third-degree collateral relative, not an ascendant.

Furthermore, the Court highlighted that the petitioners, being Gregoria’s first cousins, are fourth-degree relatives and, therefore, cannot be considered reservatarios. The right to reserva troncal is strictly limited to relatives within the third degree from the prepositus. The Court cited Florentino v. Florentino to emphasize this point:

Following the order prescribed by law in legitimate succession, when there are relatives of the descendant within the third degree, the right of the nearest relative, called reservatario, over the property which the reservista (person holding it subject to reservation) should return to him, excludes that of the one more remote… the right granted by the Civil Code in [A]rticle 811 [now Article 891] is in the highest degree personal and for the exclusive benefit of the designated persons who are the relatives, within the third degree, of the person from whom the reservable property came. Therefore, relatives of the fourth and the succeeding degrees can never be considered as reservatarios, since the law does not recognize them as such.

The Court concluded that while the properties might appear reservable in character, the petitioners could not benefit from reserva troncal because Julia was not an ascendant within the meaning of Article 891, and the petitioners were not relatives within the third degree. The proper course of action for distributing Gregoria’s estate would be under Articles 1003 and 1009 of the Civil Code, which govern intestate succession for collateral relatives. However, the Court refrained from making a definitive ruling on this matter, as the petitioners’ complaint was based solely on reserva troncal.

Additionally, the Supreme Court pointed out a significant error in the Regional Trial Court’s (RTC) decision, which had ordered the reconveyance of the properties to the petitioners and the transfer of titles in their names. The Court clarified that if reserva troncal were applicable, the RTC should have ordered the annotation of the reservable nature of the property on Julia’s titles, as the reservista has the duty to reserve and annotate the property’s character. The reservista holds legal title and dominion over the property, subject to the resolutory condition that the title is extinguished if the reservista predeceases the reservatario. This means the reservista can alienate the property, but the transferee’s rights are conditional and revocable upon the survival of the reservatarios at the time of the reservista’s death. Ownership vests in the reservatario only when the reservation takes place or is extinguished.

In conclusion, the Supreme Court denied the petition, affirming the Court of Appeals’ decision to dismiss the complaint. The Court emphasized that its decision was without prejudice to any civil action that Gregoria Mendoza’s heirs might file for the settlement of her estate or the determination of ownership of the properties in question. The case underscores the importance of strictly adhering to the requirements of Article 891 regarding reserva troncal, particularly the relationships among the prepositus, reservista, and reservatarios.

FAQs

What is reserva troncal?	Reserva troncal is a legal principle in the Philippines that ensures property acquired by an heir from an ascendant is reserved for relatives within the third degree belonging to the same family line. It prevents the property from being inherited by relatives outside that line.
Who is the ‘prepositus’ in reserva troncal?	The ‘prepositus’ is the descendant who receives property by gratuitous title (e.g., inheritance or donation) from an ascendant or sibling. This person is a key figure in determining who the reservatarios are.
Who is the ‘reservista’ in reserva troncal?	The ‘reservista’ is the ascendant who inherits the property from the prepositus by operation of law. This person has the obligation to reserve the property for the benefit of relatives within the third degree of the prepositus.
Who are the ‘reservatarios’ in reserva troncal?	The ‘reservatarios’ are the relatives within the third degree of the prepositus and belonging to the line from which the property came. They are the individuals for whom the property is reserved and who will ultimately inherit it.
What is the degree of relationship in reserva troncal?	The degree of relationship refers to the proximity of kinship between the prepositus and the potential reservatarios. Only relatives within the third degree of consanguinity from the prepositus can benefit from reserva troncal.
Can first cousins be reservatarios?	No, first cousins are fourth-degree relatives and cannot be considered reservatarios under reserva troncal. The law limits the benefit to relatives within the third degree of the prepositus.
What happens if the reservista sells the reserved property?	The reservista can sell the reserved property, but the sale is subject to the reservation. The buyer acquires the property with the condition that it will revert to the reservatarios if they survive the reservista.
What if there are no relatives within the third degree?	If there are no relatives within the third degree of the prepositus, the reserva troncal is extinguished, and the reservista becomes the absolute owner of the property. The property will then be distributed according to the ordinary rules of succession.

This case serves as a critical reminder of the precise requirements for reserva troncal, especially concerning the relationships between the involved parties. Understanding these nuances can significantly impact inheritance rights and property distribution within families.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Maria Mendoza, et al. vs. Julia Policarpio Delos Santos, G.R. No. 176422, March 20, 2013