Parish Priest of Roman Catholic Church of Victoria, Tarlac vs. Rigor

A testamentary disposition in favor of a "nearest male relative" who would study for the priesthood is deemed inoperative if no such relative exists or has manifested the required intent at the time of the testator's death, as successional rights vest at the moment of death and require the heir or legatee to be living and qualified at that specific time.

Father Pascual Rigor, a Catholic priest, died in 1935 leaving a will that distributed his estate among his sisters and a cousin, but included a controversial legacy involving four parcels of riceland. This legacy was conditioned upon a male relative pursuing a career in the priesthood, with the Parish Priest of Victoria, Tarlac, acting as administrator during intervals when no qualified legatee was available. For nearly twenty years following the probate of the will, the ricelands remained in the possession of the legal heirs because no nephew or relative of Father Rigor came forward to claim the legacy by enrolling in the seminary.

• Father Pascual Rigor died in 1935, and his will provided that four parcels of riceland in Nueva Ecija be given as a legacy to his "nearest male relative who studies for the priesthood" until ordained.
• The will stipulated that the legatee could start enjoying the land upon beginning the study of Theology and continue until death, provided he did not abandon his studies or face excommunication.
• The will further provided that during any interval where no such qualified legatee existed, the administration of the land would belong to the Parish Priest of Victoria, Tarlac, who was to accumulate the profits (minus a 5% fee) in a bank account under the name of the legacy.
• In 1940, the project of partition was approved, but the ricelands were never delivered to the Parish Priest because no relative had claimed the legacy or entered the seminary.
• In 1954, the Parish Priest of Victoria petitioned the court to be appointed administrator and for the delivery of the lands, admitting that no nearest male relative had ever studied for the priesthood.
• The legal heirs (sisters and their descendants) opposed the petition, arguing the bequest was inoperative and that they were the rightful owners.
• During the litigation, it was discovered that a grandnephew, Edgardo Cunanan, was a seminarian in 1957, but he later ceased his studies in 1961.
• The Court of Appeals ruled that the trust could only last for twenty years and that the lands should pass to the legal heirs as no legatee had qualified within that timeframe.

• The petitioner argued that the testator created a public charitable trust which should be liberally construed to remain operative and prevent intestacy.
• The petitioner contended that the Parish Priest was a trustee or a substitute devisee intended to manage the lands indefinitely until a qualified relative appeared.
• The petitioner asserted that the "interval of time" mentioned in the will allowed for a long-term administration by the church regardless of whether a relative was currently studying for the priesthood.

• The respondents argued that the bequest was inoperative because the condition (a relative studying for the priesthood) was never met by any of the testator's nearest relatives.
• The respondents claimed that the trust was a private one, not a public charitable trust, and was therefore subject to legal limitations on duration and perpetuities.
• The respondents maintained that since the legacy failed, the property should be merged into the estate and distributed to the legal heirs through intestate succession.

• Procedural Issues:

  • N/A

• Substantive Issues:

  • Whether the bequest of the ricelands to the "nearest male relative" who would study for the priesthood was operative or inoperative under the circumstances.
  • Whether the Parish Priest of Victoria, Tarlac, was entitled to the administration of the ricelands as a trustee or substitute beneficiary in the absence of a qualified relative.

• Procedural:

  • N/A

• Substantive:

  • The Supreme Court ruled the bequest inoperative. The Court held that the testator's intent, as gathered from the will, was to benefit a relative who was living at the time of his death.
  • The Court reasoned that under Article 1025 of the Civil Code, a person must be living at the moment the succession opens to be capacitated to inherit; therefore, the "nearest male relative" could not refer to individuals born indefinitely after the testator's death.
  • The Court found that the "interval of time" mentioned in the will referred to a situation where a relative living at the time of death was still in preliminary schooling (grade school or high school) and had not yet entered the seminary to study Theology.
  • Since the Parish Priest himself admitted in his 1954 and 1957 petitions that no relative had ever studied for the priesthood, the condition for the legacy failed at the time of the testator's death.
  • The Court clarified that the Parish Priest was not a substitute beneficiary but merely a temporary administrator; since the primary legacy failed, the administration by the priest also became unnecessary and inoperative.
  • Consequently, the ricelands were ordered to be merged into the estate and distributed to the legal heirs via intestate succession, pursuant to the rules on inoperative bequests and mixed succession.

• Intent of the Testator — This is the cardinal rule in the construction of wills; the testator's intention is the "life and soul" of the document and must be ascertained from the words of the will, taking into account the circumstances at the time it was made. In this case, it was used to determine that the testator only intended to benefit relatives known to him or living at his death.
• Capacity to Succeed (Article 1025, Civil Code) — To inherit, a devisee or legatee must be living at the moment the succession opens (the death of the testator). The Court applied this to limit the pool of potential "nearest male relatives" to those alive in 1935.
• Inoperative Bequests (Article 956, Civil Code / Article 888, Old Civil Code) — If a bequest for any reason is inoperative, it shall be merged into the estate, except in cases of substitution or accretion. The Court used this to justify the return of the lands to the legal heirs.
• Legal Succession (Article 960, Civil Code / Article 912, Old Civil Code) — Legal or intestate succession takes place when the will does not dispose of all the property belonging to the testator. The Court applied this to the ricelands after the legacy was declared inoperative.
• Mixed Succession — The principle that a person may die partly testate and partly intestate. The Court held that while the rest of the will was valid, the specific legacy of the ricelands fell into intestacy.

• "The intent of the testator is the cardinal rule in the construction of wills. It is the life and soul of a will. It is the first greatest rule, the sovereign guide, the polestar, in giving effect to a will."
• "To construe [the testamentary provisions] as referring to the testator's nearest male relative at anytime after his death would render the provisions difficult to apply and create uncertainty as to the disposition of his estate. That could not have been his intention."

• Santos vs. Manarang, 27 Phil. 209 — Cited to emphasize that the testator's intention is the law of the case.
• Rodriguez vs. Court of Appeals, 27 SCRA 546 — Referenced to support the principle that the determination of the testator's intention is the primary issue in probate cases.
• In re Estate of Calderon, 26 Phil. 333 — Cited to show that interpretation must follow the plain meaning of the words unless a different intention clearly appears.
• Macrohon Ong Ham vs. Saavedra, 51 Phil. 267 — Used to illustrate that if a conditional legacy does not take effect, there will be intestate succession as to the property covered by said legacy.

• Article 789, Civil Code — Relates to the interpretation of testamentary provisions and ascertaining the testator's intent from the words of the will.
• Article 1025, Civil Code — Establishes that an heir or legatee must be living at the time of the testator's death to inherit.
• Article 956, Civil Code (formerly Art. 888, Old Civil Code) — Provides that inoperative bequests are merged into the mass of the inheritance.
• Article 960(2), Civil Code (formerly Art. 912, Old Civil Code) — States that legal succession occurs when the will does not dispose of all the testator's property.
• Article 870, Civil Code — Mentioned by the Court of Appeals regarding the prohibition of perpetual trusts (though the Supreme Court decided the case on different grounds).