TESTATE ESTATE OF FATHER RIGOR VS. RIGOR


FACTS
Father Rigor, the parish priest of Pulilan, Bulacan, left a will executed and was probated by the Court of First Instance of Tarlac in its order of December 5, 1935. Named as devisees in the will were the testators nearest relatives, his three sisters. In addition, the will provided that it be adjudicated in favor of the legacy purported to be given to the nearest male relative who shall take the priesthood.

ISSUE
Whether or not the bequest in question be declared inoperative.


HELD
In the law of contracts and statutory construction, the primary issue is the determination of the testator's intention which is the law of the case. What is no clear is on how long after the testator's death would it be determined that he had a nephew who would pursue an ecclesiastical vocation. The SC held that the said bequest refers to the testator's nearest male relative living at the time of his death and not to any indefinite time thereafter. "In order to be capacitated to inherit, the heir, devisee or legatee must be living at the moment the succession opens, except in case of representation, when it is proper"  (Art. 1025, Civil Code). Inasmuch as the testator was not survived by any nephew who became a priest, the unavoidable conclusion is that the bequest in question was ineffectual or inoperative. Therefore, the administration of the ricelands by the parish priest of Victoria, as envisaged in the wilt was likewise inoperative.

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