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Succession - Sayson Vs CA

This case involved a dispute over inheritance rights between the biological children of Eleno and Rafaela Sayson and the adopted children and biological grandchild of their deceased son, Teodoro. The Court held that Doribel, as Teodoro's legitimate daughter, had the right to inherit his share of Eleno and Rafaela's estate by representation. However, Delia and Edmundo, as Teodoro's adopted children, did not have the right to inherit from Eleno and Rafaela by representation, as the relationship created by adoption does not extend to blood relatives. Therefore, only Doribel could represent Teodoro in inheriting from their grandparents, while Delia and Edmundo were

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726 views2 pages

Succession - Sayson Vs CA

This case involved a dispute over inheritance rights between the biological children of Eleno and Rafaela Sayson and the adopted children and biological grandchild of their deceased son, Teodoro. The Court held that Doribel, as Teodoro's legitimate daughter, had the right to inherit his share of Eleno and Rafaela's estate by representation. However, Delia and Edmundo, as Teodoro's adopted children, did not have the right to inherit from Eleno and Rafaela by representation, as the relationship created by adoption does not extend to blood relatives. Therefore, only Doribel could represent Teodoro in inheriting from their grandparents, while Delia and Edmundo were

Uploaded by

Kye Garcia
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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SAYSON vs.

CA
G.R. Nos. 89224-25 | January 23, 1992 | 205 SCRA 321

Adoption; Succession; Representation

Facts:

Eleno and Rafaela Sayson begot five children, namely, Mauricio, Rosario,
Basilisa, Remedios and Teodoro. Eleno died on Nov. 10, 1952, and Rafaela on
May 15, 1976. Teodoro, who had married Isabel Bautista, died on Mar. 23,
1972. His wife died nine years later, on Mar. 26, 1981. Their properties were
left in the possession of Delia, Edmundo and Doribel, all surnamed Sayson, who
claim to be their children.

On Apr. 25, 1983, Mauricio, Rosario, Basilisa and Remedios and Juana, Isabels
mother, filed a complaint for partition of the intestate estate of Teodoro and
Isabel.

Subsequently, Delia and Edmundo, both legally adopted, and Doribel as the
legitimate daughter, filed their own complaint for the partition of the intestate
estate of Eleno and Rafaela claiming that they are entitled to inherit Teodoros
share in his parents estate by right of representation.

Both cases were decided by the trial court in favor of the herein private
respondents on the basis of practically the same evidence. The CA affirmed the
lower courts decision in the case of Mauricio, et. al.; and, modified the trial
courts decision in the case of Delia, et. al. stating that Delia and Edmundo
Sayson are disqualified from inheriting from the estate of the deceased spouses
Eleno and Rafaela Sayson.

Issue: Whether private respondents are capacitated under the law to inherit
from their alleged parents and grandparents.

Held:

YES as to Doribel but NO as to Delia and Edmundo.

There is no question that as the legitimate daughter of Teodoro and thus the
granddaughter of Eleno and Rafaela, Doribel has a right to represent her
deceased father in the distribution of the intestate estate of her grandparents.
Under Article 981, to wit:

Should children of the deceased and descendants of other children who


are dead, survive, the former shall inherit in their own right, and the
latter by right of representation.

Hence, Doribel is entitled to the share her father would have directly inherited
had he survived, which shall be equal to the shares of her grandparents' other
children.

In the case of Delia and Edmundo, however, they are total strangers with
respect to the grandparents. While it is true that the adopted child shall be
deemed to be a legitimate child and have the same right as the latter, those
rights do not include the right of representation. The relationship created by
the adoption is between only the adopting parents and the adopted child and
does not extend to the blood relatives of either party.

All told, Delia and Edmundo as the adopted children and Doribel as the
legitimate daughter of Teodoro Sayson and Isabel Bautista are their exclusive
heirs and are under no obligation to share the estate of their parents with the
petitioners. Only Doribel, however, has the right of representation in the
inheritance of her grandparents' intestate estate, the other private respondents
being only the adoptive children of the deceased Teodoro.

WHEREFORE, the petition is DENIED.

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