Heirs of Conti vs CA

G.R. No. 118464. December 21, 1998

“Alexander the conqueror wanted his corpse have its hands open,
carried by doctors in the parade, and with his treasures falling on the
trail.”
Facts
• A house and lot property was co-owned by Lourdes Sampayo and
Ignacio Consti
• Lourdes died intestate
• Collateral relatives flocked upon knowledge of death of Lourdes
• Sought to claim share from the ownership
Facts
• Sampayos proved their filiation through:
- Baptismal Certificates
- Testimonies
- Marriage Certificate
• Ignacio Consti died intestate
• Heirs of Consti contested the claim of the Sampayos
Facts:
• Heirs of Consti claim that:
- Settlement of estate first before claiming
- Documents cannot prove filiation
• The RTC ruled in favor of the Sampayos
• CA affirmed the decision because rights transfer upon death
Issue
• Whether a settlement of estate is required before title of property
passes to the heirs
• Whether the Sampayos are able to prove their filiation
Rulings:
• No, settlement is not necessary to transfer title.
• The title of the property owned by a person who dies intestate passes
at once to his heirs.
• Incidental would be the right to ask for partition at any time or to
terminate the co-ownership.
Rulings:
• Yes, the Sampayos were able to prove their filiation
• Ways of Proving:
- record of birth or a parent's admission of such legitimate
filiation;
• - by any other means allowed by the Rules of Court and special
laws
Rulings
e.g.
- baptismal certificate,
- a judicial admission,
- a family Bible in which his name has been entered, common
reputation respecting his pedigree,
- admission by silence, etc…
Thank You