Friday, November 15, 2013

Intestate Estate of Amos Bellis, 20 SCRA 358

FACTS: Amos Bellis was a citizen of Texas. He had 5 legitimate children on his 1st wife whom he divorced. On his 2nd wife, he had 3 legitimate children; and 3 illegitimate children. On August 5, 1952, Amos G. Bellis executed a will in the Philippines where he disposed his properties in the following manner: (a) $240,000.00 to his first wife, Mary E. Mallen; (b) P120,000.00 to his three illegitimate children, Amos Bellis, Jr., Maria Cristina Bellis, Miriam Palma Bellis, or P40,000.00 each and (c) after the foregoing two items have been satisfied, the remainder shall go to his seven surviving children by his first and second wives. Subsequently, Amos G. Bellis died a resident of San Antonio, Texas, U.S.A. The executor of the will then submitted a proposed project of partition. Maria Cristina Bellis and Miriam Palma Bellis filed their respective oppositions to the project of partition on the ground that they were deprived of their legitimes as illegitimate children and, therefore, compulsory heirs of the deceased.

ISSUE: W/N the national law of the deceased should determine the successional rights of the illegitimate children

HELD: Yes. The illegitimate children are not entitled to their legitimes under Texas Law, being the national law of the deceased.

Article 16, par. 2, and Art. 1039 of the Civil Code, render applicable the national law of the decedent, in intestate or testamentary successions, with regard to four items: (a) the order of succession; (b) the amount of successional rights; (e) the intrinsic validity of the provisions of the will; and (d) the capacity to succeed. They provide that —

ART. 16. Real property as well as personal property is subject to the law of the country where it is situated.

However, intestate and testamentary successions, both with respect to the order of succession and to the amount of successional rights and to the intrinsic validity of testamentary provisions, shall be regulated by the national law of the person whose succession is under consideration, whatever may be the nature of the property and regardless of the country wherein said property may be found.


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

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