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On November 28, 1922, the Court of First Instance of Pampanga probated as the last will and testament of Dolores Coronel (testatrix) who named as her sole heir Lorenzo Pecson, the husband of her niece. The relatives of testatrix by consanguinity questioned the genuineness of the will on the following grounds: First, that it was improbable and exceptional that Dolores Coronel should dispose of her estate by excluding her blood relatives; and second, that if such will was not expressed in fact, it was due to extraneous illegal influence.
Whether the decedent can exclude her blood relatives in the disposition of her estate.
Yes. It is true that the ties of relationship in the Philippines are very strong, but we understand that cases of preterition of relatives from the inheritance are not rare. The liberty to dispose of one’s estate by will when there are no forced/compulsory heirs is rendered sacred by the Civil Code in force in the Philippines since 1989.
The Supreme Court held that nothing is strange in the preterition made by Dolores Coronel of her blood relatives, nor in the designation of Lorenzo Pecson(husband of her niece) as her sole beneficiary. Furthermore, although the institution of the beneficiary here would not seem the most usual and customary, still this would not be null per se.
“In the absence of any statutory restriction every person possesses absolute dominion over his property and may bestow it upon whomsoever he pleases without regard to natural or legal claim upon his bounty. If the testator possesses the requisite capacity to make a will, and the disposition of his property is not affected by fraud or undue influence, the will is not rendered invalid by the fact that it is unnatural, unreasonable, or unjust. Nothing can prevent the testator from making a will as eccentric, as injudicious, or as unjust as caprice, frivolity, or revenge can dictate.