Uson vs. Del Rosario, et al.

Successional rights are transmitted and become vested from the moment of the death of the decedent; consequently, any new rights granted by subsequent legislation (such as the New Civil Code) cannot be applied retroactively if they prejudice or impair these vested rights.

Faustino Nebreda died in 1945, leaving behind his lawful wife, Maria Uson, with whom he had no children. At the time of his death, he was living with a common-law wife, Maria del Rosario, with whom he had four illegitimate children. Following Faustino's death, the common-law family took possession of five parcels of land owned by the deceased, prompting the legal widow to file an action for recovery of ownership and possession.

• Maria Uson was the lawful wife of Faustino Nebreda, who died in 1945 owning five parcels of land in Labrador, Pangasinan.
• Faustino Nebreda left no other legal heirs except his widow, Maria Uson.
• Maria del Rosario was the common-law wife of Faustino, and they had four illegitimate children: Concepcion, Conrado, Dominador, and Faustino Jr.
• In 1931, Uson and Faustino executed a public document for separation, where Uson received a parcel of land as alimony and purportedly renounced her right to inherit any future property from Faustino.
• Upon Faustino's death in 1945, Maria del Rosario and her children took possession of the five parcels of land, excluding Uson from their enjoyment.
• The defendants argued that the illegitimate children acquired successional rights under the New Civil Code, which took effect in 1950, and that these rights should apply retroactively.
• The defendants further alleged that Uson had verbally assigned the lands to the children out of pity while Faustino was lying in state.

• Maria Uson argued that as the sole lawful heir, the ownership of the properties passed to her immediately upon her husband's death in 1945.
• She contended that the 1931 renunciation of future inheritance was legally ineffective and void.
• She maintained that any alleged verbal assignment of the lands was invalid for failing to meet the formal requirements of a donation of real property.

• The respondents argued that Uson had already relinquished her right to inherit the lands through the 1931 separation agreement.
• They claimed that the four illegitimate children were entitled to successional rights under Articles 287 and 2264 of the New Civil Code.
• They asserted that Article 2253 of the New Civil Code allows for the retroactive application of newly declared rights, even if the event giving rise to them occurred under previous law.
• They alleged that Uson made a valid assignment of the lands to the children during the deceased's wake to assuage the wrong done to them.

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether the 1931 renunciation of future inheritance by Maria Uson is valid and binding.
  • Whether the successional rights granted to illegitimate children by the New Civil Code can be applied retroactively to a death that occurred in 1945.
  • Whether the alleged verbal assignment of real property by Uson to the children is legally valid.

• Procedural:
  • N/A
• Substantive:
  • The Court ruled that the 1931 renunciation was void because future inheritance cannot be the subject of a contract nor can it be renounced before the death of the predecessor.
  • The Court held that Uson's right to the property became vested in 1945 at the moment of Faustino's death under Article 657 of the Old Civil Code.
  • The Court ruled that while the New Civil Code grants rights to illegitimate children, Article 2253 prohibits the retroactive application of such rights if they prejudice or impair a vested right of the same origin.
  • The Court found that the alleged verbal assignment of land was a donation of real property, which is void under Article 633 of the Old Civil Code because it was not executed in a public instrument.

• Vested Rights in Succession — Successional rights are transmitted from the moment of the death of the decedent, meaning the heir's ownership is legally established at that exact instant.
• Non-retroactivity of Laws Impairing Vested Rights — New laws declaring rights for the first time may only have retroactive effect if they do not impair or prejudice any vested or acquired rights.
• Prohibition on Contracts Regarding Future Inheritance — A person cannot validly renounce or enter into contracts regarding an inheritance from a person who is still alive.
• Formalities of Donation of Real Property — A donation of immovable property must be made in a public document to be valid; a verbal assignment or donation of land has no legal effect.

• "The property belongs to the heirs at the moment of the death of the ancestor as completely as if the ancestor had executed and delivered to them a deed for the same before his death."
• "If a right should be declared for the first time in this Code, it shall be effective at once, even though the act or event which gives rise thereto may have been done or may have occurred under the prior legislation, provided said new right does not prejudice or impair any vested or acquired right, of the same origin."

• Ilustre vs. Alaras Frondosa — Cited to support the principle that successional rights are transmitted and ownership is vested in the heirs at the precise moment of the decedent's death.
• Osorio vs. Osorio and Ynchausti Steamship Co. — Cited to affirm that future inheritance cannot be the subject of a contract or a valid renunciation.

• Article 657, Old Civil Code — Provides that rights to succession are transmitted from the moment of death.
• Article 633, Old Civil Code — Mandates that a donation of real property must be made in a public instrument to be valid.
• Article 2253, New Civil Code — Establishes the rule on the retroactive effect of new rights, provided they do not impair vested rights.
• Article 2264, New Civil Code — Grants successional rights to illegitimate children.
• Article 287, New Civil Code — Outlines the legal status and rights of illegitimate children.