Finals - SUCCESSION Notes Compilation

7/27/2019 Finals - SUCCESSION Notes Compilation

1/24

1

Succession Transcription Atty. Mayol

CHAPTER 4PROVISIONS COMMON TO TESTATE AND INTESTATE SUCCESSIONS

SECTION 1. - Right of Accretion

Accretion

*In property it is the process by which soil sediments carried by water are graduallydeposited to land situated on the bank of a river or on the seashore. It involves addition oripuno. The same principle is applied in succession.

Art. 1015. Accretion is a right by virtue of which, when two or more persons arecalled to the same inheritance, devise or legacy, the part assigned to the one whorenounces or cannot receive his share, or who died before the testator, is addedor incorporated to that of his co-heirs, co-devisees, or co-legatees.

- Ex.A parcel of land with an area of 900 sqm is adjudicated by the testator to his heirsA,B,C, the share of each is not mentioned. Each of them shall receive 1/3 or 300 sqm(Art. 846. Heirs instituted without designation of shares shall inherit inequal parts.) If A predecease, or has no capacity to inherit or refuses to accept, avacant portion shall exist. B and C shall receive the vacant portion in proportion tothe institution by testator. The 300 sqm shall be distrubuted equally between Band C. Thus, B and C shall receive 450 each, 350 by virtue of institution and 150 byvirtue of accretion.

Art. 1016. In order that the right of accretion may take place in a testamentarysuccession, it shall be necessary:

(1) That two or more persons be called to the same inheritance, or to the sameportion thereof, pro indiviso; and(2) That one of the persons thus called die before the testator, or renounce theinheritance, or be incapacitated to receive it.

Requisites for accretion to apply in testamentary succession- plurality of heirs - 2 or more heirs- unity of object - only one property given to the co-heirs, co-legatees, co devisees;

results in co-ownership- existence of vacant portion due to predecease, incapacity or repudiation of a co-heir

and no substitute has been instituted.- acceptance of co-heirs - accretion is not an obligation but a right, thus you can

refuse.* Refers only to the free portion.

* The heirs are co-owners of the undivided property given to them by the testator or the

heirs are the pro indiviso owners of the property

Pro indiviso - undivided, spiritual share

* If the property is indivisible, for example a car, this shall be sold and the proceeds dividedequally among the co-owners

* No accretion shall apply if there has been physical segregation or ear-marking of theproperty given or the share of the heirs can be pinpointed.

Bautista/ Lesigues/ Novabos/ Oclarit/ Po/ Rosas/ Salvador/ Tantuan / Verana


2/24

2


Ex. If A shall receive the property located in Mandaue, and B shall receive the property inCebu. If B predecease, the property in Cebu shall not go to A thru accretion.

Ex. Testator leaves all his money to A and B. A shall get the money in the left drawer and Bshall have the money in the right drawer. No accretion, there is physical segregation.

* Accretion is only based on the presumed will of the testator. The written will shall prevailover a presumed will.

- If all the requisites for accretion are existing, but the testator prohibits accretion inhis will - no accretion.

- If no requisites for accretion are existing, but the testator wrote in his will thataccretion shall apply in case of predecease - accretion shall be done.

Art. 1017. The words "one-half for each" or "in equal shares" or any others which,though designating an aliquot part, do not identify it by such description as shallmake each heir the exclusive owner of determinate property, shall not excludethe right of accretion.

In case of money or fungible goods, if the share of each heir is not earmarked,there shall be a right of accretion.

- If the testator gives the heirs a fractional share of the property or an aliquot part (ex.1/2 to A, 1/4 to B, 1/4 to C) to the heirs, accretion shall still apply since the property isstill undivided, a pro indiviso share base been given, the particular part to bereceived by the heirs cannot be pinpointed or has not been specified, and they arestill co-owners.

Art. 1018. In legal succession the share of the person who repudiates theinheritance shall always accrue to his co-heirs.

- if heirs inherit by legal succession and there is repudiation (thus no right ofrepresentation), the remaining heir/s shall receive his share, whether the principle ofaccretion is applied or not.

- Ex. Applying only legal succession:Estate is 9,000 sqm. Heirs are A,B,C. The heirs shall share in the inheritance equally andreceive 3,000. If A repudiates, then there are only two legal heirs thus only B and C shallshare in the 9,000 sqm estate, that is divide the estate by two. So B and C shall receive4,500.

Same result if accretion is applied, mas taas lang ang process.If A shall repudiate, his share shall accrue to B and C. Each shall receive 4,500, 3,000thru legal succession and 1,500 thru accretion.

In legal succession accretion shall also take place in case of incapacity if the right of

representation does not exist. In legal succession, in case of predecease, the remaining co-heir inherit in their own

right, subject to the right of representation

Art. 1019. The heirs to whom the portion goes by the right of accretion take it inthe same proportion that they inherit. (n)



3/24

3


Ex. X instituted A,B,C as his heirs to his 10,000 sqm property. Their shares are: A- , B-, and c-. A shall receive 5,000, B-2,500 and C-2,500. C died before X. How much shallA and B receive.

Proportion of A and Bs share is : or 2:1Cs share shall be distributed: 1666.67 to A; 833.33 to B

Heirs shall get A = 5,000 + 1666.66667=6666.67 and B = 2,500 +833.3333=3,333.33

Ex. X died intestate leaving behind his 12,000 sqm property to his legitimate child A andhis illegitimate children B, C. B has a son F. B repudiates his share. How much shall A, B,C and F receive.

Sharing should have been A-6,000; B-3,000; C-3,000Since B renounced his share, B and F receive nothing. His share shall accrue to his co-heirs.3,000 shall be distributed in the proportion of 2:1 2,000:1,000 to A and BA shall receive 6,000 + 2,000 = 8,000C shall receive 3,000 + 1,000 = 4,000

Or since B repudiated, divide the estate between A and C, in the proportion 2:1 (Art 983-illegitimate childs share is of legitimate childs). A= 8,000; C=4,000

Art. 1021. Among the compulsory heirs the right of accretion shall take place onlywhen the free portion is left to two or more of them, or to any one of them and toa stranger.

Should the part repudiated be the legitime, the other co-heirs shall succeed to itin their own right, and not by the right of accretion. (985)

Accretion in Testamentary Succession* Separate the legitime and the free portion* There is no accretion with respect to legitime in testamentary succession.* share of each heir with respect to the free portion of shall be in the same proportion thatthey inherit

Ex. Testator designated his children A and B and his friend F as heirs of a certainproperty he owned with an area of 120,000 sqm. B renounced his share. B has a son C.How much shall each receive?

*Separate the legitime and the free portion

Legitime: 60K thus A=30K B=30KSince B renounced his share he is not entitled to legitime and there is no right ofrepresetation. The co-heir A shall succeed to the 60K legitime in his own right since

there is no accretion with respect to the legtime in testamentarysuccession.

Free portion: 60KApply Art 846. since no designation of the shares. A,B,F shall receive the freeproportion in equal shares: 60K/3 = 20K each.Bs share shall in the free portion shall be added to the share of A and F by the rightof accretion, in the same proportion that they inherit:Proportion of As and Fs share of the free portion is 20K:20K or 1:1;



4/24

4


Bs 20K shall be distributed: 10K to A:10K to FThus share of A and F of the free portion: A=20+10= 30K; F=20+10=30K

So A shall receive 90K. 60K in his own right as legitime as a compulsory heir, 20K byvirtue of institution as a voluntary heir, and 10K by virtue of accretion.F shall receive 30K; 20K in his own right by virtue of institution and 10K by virtue of

accretion.

Art. 1022. In testamentary succession, when the right of accretion does not takeplace, the vacant portion of the instituted heirs, if no substitute has beendesignated, shall pass to the legal heirs of the testator, who shall receive it withthe same charges and obligations.

- Order of distribution of testamentary property: instituted heir, substitute,representative, accretion, intestacy

- If the instituted heir predecease, is incapacitated to inherit, or repudiates theinheritance, and no substitute has been instituted, and no right of representationexists and the requisites for accretion are not met, distribute the property using legalsuccession

Art. 1023. Accretion shall also take place among devisees, legatees andusufructuaries under the same conditions established for heirs.

SECTION 2. - Capacity to Succeed by Will of by IntestacyArt. 1024. Persons not incapacitated by law may succeed by will or ab intestato.The provisions relating to incapacity by will are equally applicable to intestatesuccession.

Art. 1025. In order to be capacitated to inherit, the heir, devisee or legatee mustbe living at the moment the succession opens, except in case of representation,when it is proper.

A child already conceived at the time of the death of the decedent is capable ofsucceeding provided it be born later under the conditions prescribed in article 41.(n)

- juridical person cannot be a legal heir and cannot make a will- Art. 41 For civil purposes, the fetus is considered born if it is alive at the time it is

completely delivered from the mother's womb. However, if the fetus had an intra-uterine life of less than seven months, it is not deemed born if it dies within twenty-four hours after its complete delivery from the maternal womb.

- Complete delivery from the maternal womb when the umbilical cord is cut- Art. 41: When a natural person attains personality

Art. 1026. A testamentary disposition may be made to the State, provinces,

municipal corporations, private corporations, organizations, or associations forreligious, scientific, cultural, educational, or charitable purposes.

All other corporations or entities may succeed under a will, unless there is aprovision to the contrary in their charter or the laws of their creation, and alwayssubject to the same. (746a)



5/24

5


- Juridical person may succeed under a will, provided they have personality at the timeof testators death, unless they are prohibited by a provision in their charter or thelaws of their creation

//JINKY

SECTION 2. - Capacity to Succeed by Will of by Intestacy

Art. 1024. Persons not incapacitated by law may succeed by will or ab intestato.

The provisions relating to incapacity by will are equally applicable to intestatesuccession. (744, 914)

Capacitated to succeed those who are not incapacitated

Art. 1025. In order to be capacitated to inherit, the heir, devisee or legatee mustbe living at the moment the succession opens, except in case of representation,when it is proper.

A child already conceived at the time of the death of the decedent is capable ofsucceeding provided it be born later under the conditions prescribed in article41. (n)

Natural persons

o Created by God with valuable assistance of your parents o Juridical personally is acquired through birtho Must be living oro At least conceived at the time the succession opens (subject to fulfillment

of Art. 41, FC) alive at the time you separated from your mothers womb

ART 41, FCFor civil purposes, the fetus is considered born if it is alive at the

time it is completely delivered from the mother's womb. However,if the fetus had an intra-uterine life of less than seven months, it isnot deemed born if it dies within twenty-four hours after itscomplete deliveryfrom the maternal womb.

Art. 1026. A testamentary disposition may be made to the State, provinces,municipal corporations, private corporations, organizations, or associations forreligious, scientific, cultural, educational, or charitable purposes.

All other corporations or entities may succeed under a will, unless there is aprovision to the contrary in their charter or the laws of their creation, andalways subject to the same. (746a)

Juridical personso Testamentary heir but NOT legal heiro Cant make a willo Must have juridical personalityo Corporations, associations, charitable institutions - Duly issued with

certificate of incorporation by SECo If public institution, government already existing/operational at the time

succession opens



6/24

6


If the laws creating that particular association or corporation (i.e.:charter, law of creation) has prohibition to inherit they CANT

INCAPATICATED TO SUCCEEDo Art. 1027 by reason of undue influence

o Art. 1028 by public moralityo Art. 1032 by reason of unworthiness

Art. 1027. The following are incapable of succeeding:(1)The priest who heard the confession of the testator during his last illness,

or the minister of the gospel who extended spiritual aid to him during thesame period;

(2)The relatives of such priest or minister of the gospel within the fourthdegree, the church, order, chapter, community, organization, or institutionto which such priest or minister may belong;

(3) A guardian with respect to testamentary dispositions given by a ward in hisfavor before the final accounts of the guardianship have been approved,

even if the testator should die after the approval thereof; nevertheless, anyprovision made by the ward in favor of the guardian when the latter is hisascendant, descendant, brother, sister, or spouse, shall be valid;

(4)Any attesting witness to the execution of a will, the spouse, parents, orchildren, or any one claiming under such witness, spouse, parents, orchildren;

(5)Any physician, surgeon, nurse, health officer or druggist who took care ofthe testator during his last illness;

(6) Individuals, associations and corporations not permitted by law to inherit.(745, 752, 753, 754a)

BY REASON OF UNDUE INFLUENCE

Applies ONLY to testamentary succession

Priest or minister conclusively presumedo Any religious congregationo Reason: because there are enterprising priest who may capitalize the

religion who might induce the testator for the purpose of selling his soul.o During his last illness sickness that resulted to the death of the testatoro There is no need to prove there is undue influence (conclusively presumed).

You only need to prove that testator had confession with him before he died.o If there is a will before the confession, then the priest is not anymore

prohibited because you cannot say that the priest has exercised undueinfluence. Because when you confess, it is believed that in that point in time,undue influence was exerted.

o If advise lang valid, not confession, no undue influence.o If testator confessed to a priest who is his son

Ex: estate is 1M, testator gave 700,000 to son (who is also apriest), subsequently executed a will, then he died (will MUST beexecuted after the confession)

Disqualification extends only to what was given by will;DOES NOT include legitime

So, he will receive of estate, 500,000 (aslegitime/compulsory heir) given to him by law



7/24

7


Remaining 200,000, cannot be given to him; disqualified tothat extent

Free portion (200,000 + 300,000) given to only son(priest), because he is the legal heir (NOT because of the will)

Relatives of such priest or minister

o Barred from inheriting covers relative of priest within the fourth degree (consanguinity), or

group where the priest is a member

Guardianso Reason: guardians have moral ascendancy over the wardo Consolation: not at all disqualified. If your guardian is your ascendant,

brother, sister or spouse, they can still receive inheritanceo Ward makes will making guardian as beneficiary before final approval of

final accounts testamentary disposition of the ward result of undueinfluence conclusively presumed

Attesting witnesso includes spouse, parent, children, or anyone claiming from these persons

Medical worker who took care of the testator before he diedo Physician, surgeon, nurse, health officer or druggist (pharmacist)o Even the children of the testator are covered in the prohibition, even if there

is moral obligation to take care of them should be regular, not isolated toqualify as someone who took care

NOTE: Kinds of incapacity1. Absolute you cannot inherit from anybody by whatever circumstance

dead people

association or entity which are not permitted by the law creating them

charter creating does not permit the institute to inherit. You are acreature of the law. And the law does not allow you. (no 6 of 1027)

2. Relative youcannot inherit from certain person under certain circumstancebut you can inherit from others

Priests

Guardians

Art. 1027 (except #6)

Individuals, associations and corporationso NOT permitted by law to inherito Absolute prohibition

Art. 1028. The prohibitions mentioned in article 739, concerning donations intervivos shall apply to testamentary provisions. (n)

BY REASON OF PUBLIC MORALITY

PERSONS MENTIONED IN ARTICLE 739, modified - AT THETIME OF THE MAKING OF THE WILL(instead of donations kaysuccession man ta)

Art. 739. The following donations shall be void:



8/24

8


(1) Those made betweenpersons who were guilty of adultery orconcubinage at the time of the donation;

(2) Those made betweenpersons found guilty of the same criminaloffense, in consideration thereof;

(3) Those made to a public officer or his wife, descedants andascendants, by reason of his office.

Incapable of succeedingo Guilty of adultery or concubinage at the time of the making of the will

No need for conviction preponderance of evidence is enougho Persons guilty of criminal offense in consideration thereofo In favor of public officers by reason of public office

//ILEEN

ARTICLE 1032.The following are incapable of succeeding by reason ofunworthiness:

(1)Parents who have abandoned their children or induced their daughters tolead a corrupt or immoral life, or attempted against their virtue;

(2)Any person who has been convicted of an attempt against the life of thetestator, his or her spouse, descendants, or ascendants;

(3)Any person who has accused the testator of a crime for which the lawprescribes imprisonment for six years or more, if the accusation has beenfound groundless;

(4)Any heir of full age who, having knowledge of the violent death of thetestator, should fail to report it to an officer of the law within a month,unless the authorities have already taken action; this prohibition shall notapply to cases wherein, according to law, there is no obligation to make anaccusation;

(5)Any person convicted of adultery or concubinage with the spouse of thetestator;

(6) Any person who by fraud, violence, intimidation, or undue influence should

cause the testator to make a will or to change one already made;(7)Any person who by the same means prevents another from making a will,or from revoking one already made, or who supplants, conceals, or altersthe latter's will; cdtai

(8) Any person who falsifies or forges a supposed will of the decedent.

These are the same enumeration youll see in 919 (disinheritance). In disinheritance, if youcommitted those grounds, whats required is reconciliation to erase those. What will erasethe grounds in case of unworthiness and therefore youll be restored to your former rightand receive what is owing to you by inheritance? Condonation. (1033)

ARTICLE 1033.The causes of unworthiness shall be without effect if the testatorhad knowledge thereof at the time he made the will, or if, having known of them

subsequently, he should condone them in writing.

To erase the ground for unworthiness which would have deprived you of the inheritance, allyou need to do is to secure the pardon of the testator and that pardon may be implied orexpress. Implied, if you are instituted as an heir by the testator notwithstanding knowledgeof the act that would have barred you from inheriting because of unworthiness. Express, if inwriting he manifests that he already pardoned the act done by the heir.Pardon will restore the right of the heir who is otherwise unworthy. Reconciliation will restorethe right of the heir who would have been validly disinherited.



9/24

9


Since they have the same grounds, if I will make a will and disinherit the heir, can I do that?Yes.Supposing I cant institute a will (therefore no disinheritance), can that heir inherit? No,assuming he committed an act of unworthiness. If the testator failed to disinherit in a will,the law will disqualify the heir being unworthy. What the testator failed to do in his lifetime,such as to disinherit, the law will effect the disqualification for him (1032), not by

disinheritance but by being unworthy.Reconciliation (in disinheritance) is easier because it need not be done in writing, unlikecondonation (in unworthiness) which requires pardon to be in writing (express: writtenpardon or implied: heir instituted in a will despite unworthiness).If ever there was an implied pardon, then he can inherit. If he was unworthy andsubsequently there was reconciliation, that would be ineffective since that is not theremedy. On the other hand, if you have been disinherited then subsequently forgiven (butno reconciliation), will your right to inherit be restored? No.

ARTICLE 1034.In order to judge the capacity of the heir, devisee or legatee, hisqualification at the time of the death of the decedent shall be the criterion.In cases falling under Nos. 2, 3, or 5 of article 1032, it shall be necessary to waituntil final judgment is rendered, and in the case falling under No. 4, theexpiration of the month allowed for the report.If the institution, devise or legacy should be conditional, the time of thecompliance with the condition shall also be considered.

This applies to testate and intestate. For instance, if youre a conditional heir and thetestamentary disposition is subject to a condition that youll pass the 2013 Bar exam(suspensive condition), when will it be determined whether the condition is fulfilled or not?

The testator died before the results were released and considering that the condition wasnot fulfilled at the time of the opening of the succession it took 3 years more from thedeath of the testator for you to pass the Bar exam.

There are 2 tests for you to inherit:1. You must be qualified to inherit at the time of the death of the testator.2. You must be qualified to inherit at the time of the fulfillment of the condition.

Ex. When the testator died, you were qualified but the condition was not yet fulfilled. After 3years, the condition was fulfilled but at that time, youre no longer qualified because youwere convicted of a crime against the spouse of the testator. You became unworthy becauseof the crime so you cannot inherit.

//RUTH

Art. 1038. Any person incapable of succession, who, disregarding the prohibitionstated in the preceding articles, entered into the possession of the hereditaryproperty, shall be obliged to return it together it its accessions.He shall be liable for all the fruits and rents he may have received, or could havereceived through the exercise of due diligence. (760a)

Art. 1039. Capacity to succeed is governed by the law of the nation of the

decedent. (n)

Art. 1040. The action for a declaration of incapacity and for the recovery of theinheritance, devise or legacy shall be brought within five years from the time thedisqualified person took possession thereof. It may be brought by any one whomay have an interest in the succession. (762a)

What is legal effect if the person is incapacitated but he insists in the possession andenjoyment of the property, both capacitated what is the sanction? Wa kay katungod kay



10/24

10


incapicated ka nevertheless he is in possession and enjoying the possession? What is thelegal effect?Very practical, he is duty bound to return the property. Not only, but including theaccessions, meaning the improvement by nature, as well as the fruits of that property whichhave been earned in the exercise of reasonable diligence. Importantly i-uli wa man kaykatungod. What about accessions? These are fruits but increments done by nature that is

still included.If the xxx are prejudiced by the failure or neglect to return the property what do you do?You resort to court action.What is the name?Action for the declaration of incapacity and Recovery of real property, if ever itinvolves real property.At the same time reconveyance of the property which is possessed by him without authorityof law. You pray for the return of the property.

The action should brought WITHIN 5 YEARS from the time the DISQUALIFIED heir tookPOSSESSION thereof.

The action must be BOTH for declaration AND recovery. If one brings the action only for adeclaration of incapacity, he cannot recover possession. The action must include recovery ofaccessions, rentals, and fruits.Anyone who may have interest in the succession (the person who would inherit in place ofthe incapacitated heir) may bring the action.

SECTION 3. - Acceptance and Repudiationof the Inheritance

Art. 1041. The acceptance or repudiation of the inheritance is an act which ispurely voluntary and free. (988)

What is acceptance?The acceptance of the inheritance under the civil code is the act by which the person calledto succeed by universal title either by the testator or by law manifests his will of making hisown the universality of the rights and obligations before transmitted to him.(Tolentino)

Just like contracts, it should be freely entered to. It should be free and voluntary. Thereshould be no vitiated consent.It is likewise retroactive.Decedent died September 1, then 24 days from his death, you come to this sight as an heirthat youll accept, the other one repudiates, you did it today September 25, when does theheir deemed to accepted or repudiated the inheritance?It dates back to September 1, and not today. Why retroactive to September 1? According to777, the right to the succession is transmitted at the moment of the death of the decedent.So that to avoid in appoint in time where there is no owner. Ownership is characterized bycontinuity. To avoid a vacuum.

Art. 1042. The effects of the acceptance or repudiation shall always retroact tothe moment of the death of the decedent. (989)

Art. 1043. No person may accept or repudiate an inheritance unless he is certain

of the death of the person from whom he is to inherit, and of his right to theinheritance. (991)Still a description, same as the above provisions.What are the conditions precedent to be observed before succeeding?

(1) Certainty of the death of the person from whom one is to inherit(2) You must be certain of our right that you can succeed

One must be certain to his right to succeed because a will is ambulatory. It is subject torevocation.



11/24

11


Art. 1044. Any person having the free disposal of his property may accept orrepudiate an inheritance.Any inheritance left to minors or incapacitated persons may be accepted by theirparents or guardians. Parents or guardians may repudiate the inheritance left totheir wards only by judicial authorization.The right to accept an inheritance left to the poor shall belong to the persons

designated by the testator to determine the beneficiaries and distribute theproperty, or in their default, to those mentioned in Article 1030. (992a)

Art. 1045. The lawful representatives of corporations, associations, institutionsand entities qualified to acquire property may accept any inheritance left to thelatter, but in order to repudiate it, the approval of the court shall be necessary.(993a)

Art. 1046. Public official establishments can neither accept nor repudiate aninheritance without the approval of the government. (994)

Art. 1047. A married woman of age may repudiate an inheritance without theconsent of her husband. (995a)

Take note in repudiation, the above provision provides that they can only repudiate withjudicial approval or authorization.They can accept without judicial approval. The guardians for their wards. Agents orrepresentative of corporations, associations, and institutions.

Art. 1048. Deaf-mutes who can read and write may accept or repudiate theinheritance personally or through an agent. Should they not be able to read andwrite, the inheritance shall be accepted by their guardians. These guardians mayrepudiate the same with judicial approval. (996a)

Art. 1049. Acceptance may be express or tacit.An express acceptance must be made in a public or private document.A tacit acceptance is one resulting from acts by which the intention to accept isnecessarily implied, or which one would have no right to do except in the capacityof an heir.Acts of mere preservation or provisional administration do not imply anacceptance of the inheritance if, through such acts, the title or capacity of an heirhas not been assumed. (999a)Acceptance may be EXPRESS or TACIT (implied) and third which is unlisted is PRESUMED(Art. 1057).

Art. 1050. An inheritance is deemed accepted:(1) If the heirs sells, donates, or assigns his right to a stranger, or to his co-heirs, or to any of them;(2) If the heir renounces the same, even though gratuitously, for thebenefit of one or more of his co-heirs;(3) If he renounces it for a price in favor of all his co-heirs indiscriminately;

but if this renunciation should be gratuitous, and the co-heirs in whosefavor it is made are those upon whom the portion renounced shoulddevolve by virtue of accretion, the inheritance shall not be deemed asaccepted. (1000)

Instances were an inheritance is deemed accepted:1. If the HEIR sells, donates, or assigns to ANY PERSON.2. If the heir RENOUNCES even though gratuitously for the benefit of his co-heirs.3. Renounces for a price in favor of all his co-heirs indiscriminately



12/24

12


There must have been a point in time in which he accepted because to sell, donate orassign, one must be the owner. If you are not the owner of the thing, you cannot sell ortransfer ownership. Same in the case of donation, donation inter vivos, one must be theowner.In renunciation, there must be some BENEFITED. It is considered as implied acceptance.Because you are dictating were the property will go or will be transferred. It presupposes

that you accept it for the benefit of someone else.There is a price or consideration. It is clear that when you renounce for a price, there is aconsideration. You accepted it because there is a price.

Art. 1051. The repudiation of an inheritance shall be made in a public or authenticinstrument, or by petition presented to the court having jurisdiction over thetestamentary or intestate proceedings. (1008)

The repudiation shall be made in a public or authentic instrument.Why should it be made in a public document? Is a public document not authentic? Why is it

stated in the law?Authentic is placed to emphasize the importance that it is genuine and is duly proved. Thatis why it is strict in repudiation.

Art. 1052. If the heir repudiates the inheritance to the prejudice of his owncreditors, the latter may petition the court to authorize them to accept it in thename of the heir.The acceptance shall benefit the creditors only to an extent sufficient to cover theamount of their credits. The excess, should there be any, shall in no case pertainto the renouncer, but shall be adjudicated to the persons to whom, in accordancewith the rules established in this Code, it may belong. (1001)

The remedy of the creditor of the heir-debtor is to petition the court. The petition containsthat the creditor be allowed to accept the inheritance in the name of the heir to accept theamount to the extent of the credit. You can recover only to the extent of the credit.

Art. 1053. If the heir should die without having accepted or repudiated theinheritance his right shall be transmitted to his heirs. (1006)

Art. 1054. Should there be several heirs called to the inheritance, some of themmay accept and the others may repudiate it. (1007a)Combine these two provisions. If the heir died without acceptance or repudiation, the right istransmissible to his heirs. It is up to his heirs to accept or repudiate the inheritance. Theyrefer to their individual capacity to accept or repudiate. Art. 1054 is based on Art. 1053.

Art. 1055. If a person, who is called to the same inheritance as an heir by will andab intestato, repudiates the inheritance in his capacity as a testamentary heir, heis understood to have repudiated it in both capacities.Should he repudiate it as an intestate heir, without knowledge of his being atestamentary heir, he may still accept it in the latter capacity. (1009)

The basis of intestacy is the presumed will, had he been able to distribute it in his lifetimevis--vis in testamentary which there is a will which is the express will of the testator.

Repudation of his capacity as a testamentary heir.During the lifetime of B, had a will in which the only disposition of his will is that the freeportion goes to his only son A. Let us solve first the free portion. The free portion is theportion after all the legitime is satisfied. The legitime is half of the estate. The estate is100k. 50k goes to A as his legitime. So there is a free portion of 50k. A chose to repudiatethe disposition of the will to which the free disposable free portion would only go to him andto no one else. By will, the express will of the testator, which was in the last will andtestament. .. what was given to him expressly by the testator, he rejected it. What happensto your legal share? Who gave you the legal share? It is the law based on the presumed will.



13/24

13


If your legal share is based on the presumed will who will prevail? Is it the presumed will? Orthe express will? The express will will prevail. Since you repudiated what was given to youby will, which founded by express will of your father the testator, then you are deemed tohave renounced also what was given to you based by law based on the presumed will.

Therefore you are deemed to have repudiated it likewise. So repudiation which is basedon the express will carries with it repudiation on the presumed will.

But the same does not apply the other way around. As long as there is no fore knowledge ofhim being a testamentary heir.

Art. 1056. The acceptance or repudiation of an inheritance, once made, isirrevocable, and cannot be impugned, except when it was made through any ofthe causes that vitiate consent, or when an unknown will appears. (997)

Art. 1057. Within thirty days after the court has issued an order for thedistribution of the estate in accordance with the Rules of Court, the heirs,devisees and legatees shall signify to the court having jurisdiction whether theyaccept or repudiate the inheritance.If they do not do so within that time, they are deemed to have accepted theinheritance. (n)

//THIRDIE

Art. 1055. If a person, who is called to the same inheritance as an heir by will andab intestato, repudiates the inheritance in his capacity as a testamentary heir, heis understood to have repudiated it in both capacities.

Should he repudiate it as an intestate heir, without knowledge of his being atestamentary heir, he may still accept it in the latter capacity.

Repudiation of the share as given in the will is an implied repudiation of ones sharein the estate given by law or intestate.

(wa man gani ka nidawat sa gihatag og tuyo sa imong amahan, what more sa ihatag salaw.) But repudiation of what is given by law does not mean repudiation of what was given

expressly by will provided he repudiates without knowledge that he is also atestamentary heir.

Art. 1056. The acceptance or repudiation of an inheritance, once made, isirrevocable, and cannot be impugned, except when it was made through any ofthe causes that vitiate consent, or when an unknown will appears. (997)

Art. 1057. Within thirty days after the court has issued an order for thedistribution of the estate in accordance with the Rules of Court, the heirs,devisees and legatees shall signify to the court having jurisdiction whether theyaccept or repudiate the inheritance.If they do not do so within that time, they are deemed to have accepted the

inheritance. Presumption: Within 30 days after court order and the heirs did not act whether to

accept or repudiate = deemed an acceptance

Section 4. Executors and Administrators

Art. 1058. All matters relating to the appointment, powers and duties ofexecutors and administrators and concerning the administration of estates ofdeceased persons shall be governed by the Rules of Court.



14/24

14


Art. 1059. If the assets of the estate of a decedent which can be applied to thepayment of debts are not sufficient for that purpose, the provisions of Articles2239 to 2251 on Preference of Credits shall be observed, provided that theexpenses referred to in Article 2244, No. 8, shall be those involved in theadministration of the decedent's estate.

Art. 1060. A corporation or association authorized to conduct the business of atrust company in the Philippines may be appointed as an executor, administrator,guardian of an estate, or trustee, in like manner as an individual; but it shall notbe appointed guardian of the person of a ward.

Section 5. Collation

Art. 1061. Every compulsory heir, who succeeds with other compulsory heirs,must bring into the mass of the estate any property or right which he may havereceived from the decedent, during the lifetime of the latter, by way of donation,or any other gratuitous title, in order that it may be computed in thedetermination of the legitime of each heir, and in the account of the partition.

In rel. toArt. 909. Donations given to children shall be charged to their legitime.Donations made to strangers shall be charged to that part of the estate of which thetestator could have disposed by his last will.Insofar as they may be inofficious or may exceed the disposable portion, they shallbe reduced according to the rules established by this Code.

Formula:Gross Estate-charges, debtsNet Estate+ collationable donation, if there is anyNet distributable estate

Collationable donation any donations or gratuitious title(called advance legitimes)received by compulsory heirs inter vivos must be brought to the estate for thedetermination of the legitimes

Donation inter vivos during lifetime of the donor, effective during lifetime as soon asthe contract is perfected as compared to mortis causa which is effective only upon death

Forms: Art. 748 749 (if not followed void)Art. 748. The donation of a movable may be made orally or in writing.

An oral donation requires the simultaneous delivery of the thing or of the documentrepresenting the right donated.

If the value of the personal property donated exceeds five thousand pesos, thedonation and the acceptance shall be made in writing, otherwise, the donation shallbe void. (632a)

Art. 749. In order that the donation of an immovable may be valid, it must be madein a public document, specifying therein the property donated and the value of thecharges which the donee must satisfy.

The acceptance may be made in the same deed of donation or in a separate publicdocument, but it shall not take effect unless it is done during the lifetime of thedonor.

If the acceptance is made in a separate instrument, the donor shall be notifiedthereof in an authentic form, and this step shall be noted in both instruments.



15/24

15


Personal property verbal acceptance but if exceeding 5k, acceptance must bein writing

Immovable property public instrument

Other gratuitous title these are those other than donation Example: the father provided for the materials and labor for the repair of one of

the heirs house. Such cost is collationable. This is indirect donation.

Other examples: condonation of an heirs debt, purchase of a land and registeringwith the name of an heir these are collationable

EXCLUSIONS FROM COLLATION these are non-collationable items: Art. 1063, 65, 66, 67 , 681. Property left by will (Art. 1063)

Art. 1063. Property left by will is not deemed subject to collation, if thetestator has not otherwise provided, but the legitime shall in any caseremain unimpaired.

Because a collationable item should be received only during the lifetime of thetestator. In the case of a will, a property is only received upon death.

2. Art. 1065

Art. 1065. Parents are not obliged to bring to collation in the inheritance oftheir ascendants any property which may have been donated by the latterto their children.

A (donor)

Donation D cannot collate the donated propertybecause he is not the recipient

C (donee)

3. Art. 1066Art. 1066. Neither shall donations to the spouse of the child be brought tocollation; but if they have been given by the parent to the spouses jointly,the child shall be obliged to bring to collation one-half of the thing donated.

Donated property P 2MA (donor)

D W wife (donee)

GR: P 2M property should not be collated. Same reason as Art. 1065, D is not therecipient.

EXC: if the property was donated JOINTLY, it was donated to both spouses. D shallbring to collation one-half of the thing donated. Here, only P 1M shall be collated.

4. Art. 1067Art. 1067. Expenses for support, education, medical attendance, even inextraordinary illness, apprenticeship, ordinary equipment, or customary

gifts are not subject to collation. Support expenses for sustenance, clothing, etc.

5. Art. 1068Art. 1068. Expenses incurred by the parents in giving their children aprofessional, vocational or other career shall not be brought to collationunless the parents so provide, or unless they impair the legitime; but whentheir collation is required, the sum which the child would have spent if he



16/24

16


had lived in the house and company of his parents shall be deductedtherefrom.

this is legal obligation of the parents, part of support, transportation going toschool and back

//DONN

ARTICLE 1073. The donee's share of the estate shall be reduced by an amountequal to that already received by him; and his co-heirs shall receive anequivalent, as much as possible, in property of the same nature, class andquality.

A died intestate, survived by his legitimate children X, Y, and W. The net value of his estateis Php70,000. During his lifetime he made the following donations: W 20,000, F (stranger) 30,000. Distribute.

Solution:

Legitime 60,000X 20,000

Y 20,000W (20,000) (received intervivos)

Distribution:LEGITIME FDP

X 20,000 + 10,000 = 30,000Y 20,000 + 10,000 = 30,000Z - + 10,000 = 10,000

70,000

All donations inter vivos are to be collated except when they fall under the exceptions wehave enumerated. Donation inter vivos given to the compulsory heir are charged to thelegitime while donation to strangers are charged to the free portion.

If A (testator) states in his will that the portion given intervivos to W shall not be collated, isthe stipulation void? No. The collation is based on the presumed will and if compared to theexpress will of the testator, the express will shall prevail. Where the testator provides thatthe donation to W shall not be collated, it means that the 20,000 wont be charged to theadvanced legitime but instead charged to the free portion.


Gross Estate

70,000 Charges 0 N NetEstate 70,000+ Collationable Donations +

20,00030,000

Net Distributable Estate120,000

Free Disposable

Portion60,000 30,000 (donation toF)

30,000 3

10,000


17/24

17


If the donation inter vivos exceeds the legitime, the excess are to be returned because thedonations are considered inofficious.

ARTICLE 1070. Wedding gifts by parents and ascendants consisting of jewelry,clothing, and outfit, shall not be reduced as inofficious except insofar as they mayexceed one-tenth of the sum which is disposable by will.

A B C (wedding gift - 40,000)

Solution:

Distribution:LEGITIME FDP

A 40,000 + 36,000 = 76,000B 40,000 + 36,000 = 76,000C 12,000 + 36,000 = 48,000

200,000

The 10% shall be charged from the FDP. The amount exceeding 10% of the sum which isdisposable by will shall be treated as advance legitime (40,000 12,000 = 28,000).

//RUTH

Art. 1078. Where there are two or more heirs, the whole estate of the decedentis, before its partition, owned in common by such heirs, subject to the payment ofdebts of the deceased.

(Some of the few facts are missing coz na late ug record gamay)You cant pinpoint your share of 1/5 because there is yet no division because it is still under

co-ownership. The aliquot part, or the ideal share, or the proportional share, or the physicalshare, or abstract share are used interchangeably.

If this property is 1 hectare then it is 10,000 square meters and 1/5 of that is 2,000 squaremeters. If you will be asked to pinpoint your 1/5 aliquot part of the share then you cannotpinpoint actually that 1/5 because it is still in co-ownership and there is no partition.


Legitime 120,000A 40,000B 40,000C (28,000) advance

legitime12,000

F


18/24


19/24

19


Art. 1088. Should any of the heirs sell his hereditary rights to a stranger beforethe partition, any or all of the co-heirs may be subrogated to the rights of the

purchaser by reimbursing him for the price of the sale, provided they do so withinthe period of one month from the time they were notified in writing of the sale bythe vendor.

Y200,000 P 100, 000A B C D E

This is the property owned in common by A,B,C,D and E. There is no partition yet and eachheir has a 1/5 share.Q: Is it legally permissible if one of the co-heir who is also the co-owner to dispose by way ofsale of his hereditary right?ANS: YES! Even if the property is not partitioned yet. You only dispose of your hereditaryright not the specific property because you cant pinpoint. You just have to describe yourproperty and say my hereditary right to the property above described equivalent to 1/5. Youcant specifically determine the metes and bounds of your share there being no partition.

In this case, P purchased the hereditary right for 100,000.

Q: What are the right of B,C,D and E?ANS: They can exercise the right of legal redemption. They can redeem that whether or notP will agree. This legal redemption is by operation of law.

For legal redemption to apply, the following requisites must all be present:

a. There must be two or more heirs plurality of heirsb. One of the co-heir sold his hereditary right to a strangerc. The sale was made before the partition of the propertyd. That the buyer is a stranger any person other than the co-owners concernede. The redemptioner must reimburse the purchaser the value of the purchase price

Q: if there is already partition, what will happen?ANS: There can still be legal redemption not under article 1088 but this time under article1620 will apply.

Q: Supposing A sold it to another co-heir who is B. Can there be legal redemption?ANS: NO! The redemption is permitted because the law frowns on co-ownership. Therefore,if you sell your share to B then there will only be 4 co-owners left. But if you sold it to P, thenthere will still be 5 co-owners. Thats why the law discouraged co-ownership because it is thesource of conflict of rights.

That is why legal redemption is permitted in order to minimize the number of co-owners.

Q: Supposing B and C decided to redeem. Who shall be favored?ANS: Nobody is favored. B and C can redeem and they will divide the property in equalshares. Therefore, of 1/5 belongs to B and the other half to C. And when it comes topartition, B and C will have a higher amount of share. If the property is 10,000 squaremeters then each of the co-owner is entitled to 2,000 square meters. B and C will bereceiving 3,000 square meters each.

Q: Can B,C,D and E redeem at the same time?



20/24

20


ANS: Yes! They have to divide the 1/5 share into 4. So, if 2,000 square meters then each ofthe co-owner will have an increment of 500 square meters. By the time of partition they willbe receiving 2,500 square meters each. They stand in equal footing when it comes toredemption.

If a co-owner will decide to redeem he has to do it within the prescriptive period. Do that

within 30 days from notice in writing.

Q: Supposing that you had knowledge that it was sold by your co-heir. Will that alone besufficient?ANS: Its not sufficient for it has to be within 30 days from the notice in writing. It isMANDATORY!

Q: Supposed P purchased it for 100,000 and later on P sold it to Y for 200,000. Which valueis to be paid for the purpose of redeeming the property?ANS: only the 100,000. I this case, it is the fault of Y because una siya nipalit he should haveknown that it is subject to the right of the other co-heirs. Hence, Y bought it at his own risk.

Do not ever think that after partition it could no longer be done. The only difference is that ifthe transfer of the property by way of sale took place after the partition then we are notgoing to use article 1088 rather we are going to use article 1620.

In Partition we have to hire a private surveyor to determine the metes and bounds. It isbecause in your title it is only stated more or less and its not the accurate area.

Art. 1091. A partition legally made confers upon each heir the exclusiveownership of the property adjudicated to him.

Q: What are the effects of partition?Ans: It confers exclusive ownership to the owner whom the property is adjudicated. Afterthe partition you are already the OWNER.

Article 1091 and 1092 are the twin effects of partition.

Art. 1092. After the partition has been made, the co-heirs shall be reciprocallybound to warrant the title to, and the quality of, each property adjudicated.

Another effect is article 1092. Ig human ug partition nila B,C,D and E they have to warrantagainst eviction. All the previous co-owners will have to warrant against eviction. Warrantthe peaceful possession and enjoyment of the property. You assure the co-owner that he willnot be deprived of his possession and enjoyment.

Eviction is by virtue of final judgment based on a right existing prior to the partition, the co-owner is deprived either totally or partially of the thing adjudicated to him. Notice of final

judgment is this applicable here in Succession? Not necessarily, it is enough that you aredisturbed. Not necessarily to be evicted by somebody else whom may have a rightful claim

over the share adjudicated to you. So, kana lang ang pagdisturb nimo kay apil nana siya.Notice of final judgment is not required in succession in cases of eviction. There is alreadyeviction if you are disturbed in your possession and enjoyment. And as to quality also youhave to warrant against hidden defects with respect to movables.

//Ching



21/24

21


Art. 1098. A partition, judicial or extra-judicial, may also be rescinded on accountof lesion, when any one of the co-heirs received things whose value is less, by atleast one-fourth, than the share to which he is entitled, considering the value ofthe things at the time they were adjudicated.

There is a contract valued 10,000. You were given only 7,500 instead of 10,000,alkansi ka ug . Can you rescind?

No, because that is equivalent to . It has to be more than . You own a room that is leased for 10,000 per month. Gipa abangan lang ug 7,000.

Can you rescind the contract of lease?

Yes, because the extent of lesion is more than . Sa ato pa class, kanang pag bahin-bahin bale wala rana kay alkansi man ko. There is a

lesion, I have suffered, I am one of the co-owne.

How much lesion must that co-owner suffer to warrant rescission?

Different with rescission of contract in general. In Art. 1098, exactly is sufficient. In contracts, in general, it should be more than .

You rescind the partition by reason of economic damage or prejudice of a co-owner.

The co-owner sustained financial damage of exactly . Therefore, duha ra gyud angbuhaton:1. Rescind the partition2. Indemnify the co-owner of the amount of deficiency

- The other co-owners will contribute an amount in proportion to what theyreceived (proportionate to their interest).

If a co-owner received only 80,000 instead of 100,000, lesion is 20,000 or 1/5, canthe co-owner rescind?

No. is the minimum.

Remedy: ask for damages from the other co-owners.

You may also ask for the deficiency from the other co-owners.

Art. 1103. The omission of one or more objects or securities of the inheritanceshall not cause the rescission of the partition on the ground of lesion, but the

partition shall be completed by the distribution of the objects or securities which

have been omitted. Is there such thing as preterition in partition?

Yes. Pag binahinay na, wa na ka hatagi. It was intended for you to receive something but you

were not given anything. If you are preterated, you can demand the equivalent value you are suppose to receive.

You cannot annul or rescind, unless if there is bad faith or fraud. Supposing there is a person who is not an heir but was given your share, there is

intrusion. A stranger to the inheritance became an heir of a property he/she is notsupposed to receive.- Status: it is void with respect to that particular person.

There are suppose to be only 5 heirs but it became 6 because naay lain ni apil, si X.That partition is void with respect to X only. You cannot entirely nullify the partition.

Art. 924. All things and rights which are within the commerce of man may bebequeathed or devised.

Object of a legacy or devise (Art. 924)o Legacy- personal propertyo Devise- immovable property

Art. 925. A testator may charge with legacies and devises not only his compulsoryheirs but also the legatees and devisees.



22/24

22


The latter shall be liable for the charge only to the extent of the value of thelegacy or the devise received by them. The compulsory heirs shall not be liablefor the charge beyond the amount of the free portion given them.

Persons charged to give the legacy or devise:1. Any person charged by the testator

- May be the compulsory heirs, may be the legatee or the devisee.

- Persons who may have interest over the property may be the object of thetestators charge.

Example, walay gisugo ang testator. Walay gsugo na compulsory heir, voluntary heir,legatee or devisee. Ni ingnon lang siya to give a legacy to Juan dela Cruz in theamount of P50,000. Nobody is charged.

If nobody is charged, the estate will give it through the executor oradministrator.

2. The estate- Executor: person appointed by the testator in his last will and testament.- Administrator: if there is no executor appointed. The court will appoint an

administrator.

You were given 1M legacy but you were charged by the testator to give 400,000 in

favor of Juan dela Cruz. 1M is the legacy while the 400,000 is the sub-legacy.

Art. 927. If two or more heirs take possession of the estate, they shall besolidarily liable for the loss or destruction of a thing devised or bequeathed, eventhough only one of them should have been negligent.

You are in possession of the thing. Gi-tagaan ka tnuod pero pa taga-on ka ug autoniya unya gawas sa inyong ka kiat, naguba.

There were siblings who took possession of the thing, a car, to be given to a legatee.Gi-dala nila ang auto pag pamista nila unya na disgrasya nuon. Ang nag-kiat ang gadrive ra, ang usa natulog.

The heirs who took possession of the property object of a legacy will besolidarily liable.

Art. 911.

Order of payment of the net hereditary estate:1. Legitimes2. Donations inter vivos3. Preferred legacies and devises4. All other legacies and devises pro rata

Art. 950. If the estate should not be sufficient to cover all the legacies anddevises, their payment shall be made in the following order:

(1) Remuneratory legacies and devises;(2) Legacies and devises declared by the testator to be preferential;(3)Legacies for support;

(4) Legacies for education;(5)Legacies or devises of a specific, determinate thing which forms a part of

the estate;(6)All others, pro rata.

Estate is 50,000. Unya daghan kaau siya ug gi-hatag.A= 40,000 for educationB= 30,000 for supportC= 20,000 remunerative legacy



23/24

23


D= 10,000 preferred legacyDistribute the legacies.

1. Remunerative= 20,0002. Preferred= 10,0003. Support= 20,000

Kung asa ra kutob ang kwarta.

When to use Art. 950 and when to use Art. 911?o If in the problem there is a legitime to be given, that is involved, associated with

legacies and devises to be given, and the estate is not enough, always use Art. 911.- If there is a legitime to be satisfied, associated with legacies or devises, use Art.

911.- In Art. 950, there are no legitime and donation inter vivos involved. It is purely

legacies and devises.o Supposing there is no legitime to be satisfied but the legacies and the devises are

again associated with donation inter vivos, use Art. 911.- If their legitime and donation inter vivos interfering with the legacies and devises,

use Art. 911.o If it concerns legacies and devises only, no interference of the legitime and donation

inter vivos, use Art. 950.

In Art. 911, maka-dawat ang tana pero magka-minus kay pro rated k yang estatekuwang. In Art. 950, naay di maka-dawat kay kung asa kutob ang asset, mao ra man na.

//Eunice

Art. 930. The legacy or devise of a thing belonging to another person is void, ifthe testator erroneously believed that the thing pertained to him. But if the thingbequeathed, though not belonging to the testator when he made the will,afterwards becomes his, by whatever title, the disposition shall take effect.

Art. 931. If the testator orders that a thing belonging to another be acquired inorder that it be given to a legatee or devisee, the heir upon whom the obligationis imposed or the estate must acquire it and give the same to the legatee or

devisee; but if the owner of the thing refuses to alienate the same, or demandsan excessive price therefor, the heir or the estate shall only be obliged to givethe just value of the thing.

Discussion on Art. 930-31.

Art. 932. The legacy or devise of a thing which at the time of the execution of thewill already belonged to the legatee or devisee shall be ineffective, even thoughanother person may have some interest therein.If the testator expressly orders that the thing be freed from such interest orencumbrance, the legacy or devise shall be valid to that extent. (866a)


Erroneously believingthat the object is his(Art. 930)

With knowledge that

it is NOT his (Art.

931)

If that another person

continuously owns it

Subsequently acquires

the thing

VOID(cant give what u do notown)VALID

There is an order for

its acquisition &

successful

VALID

It cant be acquired

(price is exorbitant)

Thingsowned byanother

VALID(give just value)


24/24

24


Art. 933. If the thing bequeathed belonged to the legatee or devisee at the timeof the execution of the will, the legacy or devise shall be without effect, eventhough it may have subsequently alienated by him.If the legatee or devisee acquires it gratuitously after such time, he can claimnothing by virtue of the legacy or devise; but if it has been acquired by oneroustitle he can demand reimbursement from the heir or the estate. (878a)

//Reeld, Zeny

B ti t / L i / N b / O l it/ P / R / S l d / T t / V

Already owned byLEE or DEE at thetime of making thewill(Art. 932)

Already owned by

LEE or DEE at the

time of making the

will but alienated the

same to somebody

else and reacquired

it: (Art. 933)

VOID

through Onerous title

through Gratuitous title

Thingsowned byanother

can claim nothing

LEE/DEE can ask for

reimbursement

from the estate

Documents

Finals - SUCCESSION Notes Compilation