Republic of the Philippines v. Guzman
326 SCRA 90
In 1968 Simeon died leaving to his sole heirs, Helen and David, his estate. In 1970, Helen and David executed a Deed of Extrajudicial Settlement of the Estate of Simeon Guzman dividing and adjudicating to them all the property belonging to the estate of Simeon.
After eleven years from the time the said deed of extrajudicial settlement was
executed, Helen executed a Quitclaim Deed assigning, transferring and conveying to
her son David her undivided one-half interest on all the parcels of land subject matter of
the said deed of extrajudicial settlement.
ISSUE: Whether or not Helen validly repudiated her right to inherit from the decedent
There is no valid repudiation of inheritance as Helen had already accepted her
share of the inheritance when she, together with David, executed a Deed of
Extrajudicial Settlement of the Estate of Simeon Guzman in 1970 dividing and
adjudicating between the two of them all the property in Simeon’s estate. Article 1056 of the Civil Code provides that “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.”
In this case, there is no showing 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 Article 1056, Helen cannot belatedly execute an instrument
that has the effect of revoking or impugning her previous acceptance of her one-half
share of the subject property from Simeon’s estate. Hence, the quitclaim deeds that she
executed eleven years after she had accepted the inheritance have no legal force and
effect.
