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Vda. de Aranas vs.

Vicente Aranas
G.R. No. L-56249 May 29, 1987
Fr. Teodoro Aranas June 6, 1946 January 19, 1953
C. The special administration of the remainder of the estate of the testator
by Vicente Aranas, a faithful and serviceable nephew and designating
him also as recipient of 1/2 of the produce of said properties after
deducting the expenses for the administration and the other 1/2 of the
produce to be given to the Catholic Church for the eternal repose of the
testator's soul. Said pertinent provision reads as follows:

xxx Vicente B. Aranas (Tingting), because he is a faithful and serviceable


nephew, should be the first special administrator of said properties,
without bond, until his death or until he should not want to hold the said
office anymore xxx
• Vda. de Aranas et. al filed a "Motion for the Declaration of Heirs and
Partition; and for Removal of the Administrator (Vicente Aranas) and/or for
his Permission to Resign, and appointment of His Successor"

• They contended that “perpetual inalienability and administration of the


portion of the estate of the late Rev. Fr. Teodoro Aranas, administered by
Vicente Aranas, is null and void after twenty years from January 19, 1954.”

Article 870. The dispositions of the testator declaring all or part of the
estate inalienable for more than twenty years are void.
ISSUE

Whether or not the designation of Vicente


Aranas as usufructuary is null and void.
RULING
 NO, it is valid

 Vicente Aranas as a usufructuary has the right to enjoy the property of his
uncle with all the benefits which result from the normal enjoyment (or
exploitation) of another's property, with the obligation to return, at the
designated time, either the same thing, or in special cases its equivalent.
Art. 603. Usufruct is extinguished:
(1) By the death of the usufructuary, unless a contrary intention clearly appears;
(2) By the expiration of the period for which it was constituted, or by the fulfillment of any
resolutory condition provided in the title creating the usufruct;
(3) By merger of the usufruct and ownership in the same person;
(4) By renunciation of the usufructuary;
(5) By the total loss of the thing in usufruct;
(6) By the termination of the right of the person constituting the usufruct;
(7) By prescription.
 The right of Vicente to enjoy the fruits of the properties is temporary and
therefore not perpetual as there is a limitation namely his death or his refusal.

“A usufruct is meant only as a lifetime grant. Ordinarily, therefore, the


usufruct is extinguished upon the death of the usufructuary. Unlike a natural
person, the lifetime of a corporation or association may be extended
indefinitely. For this reason, the law limits the life of the usufruct to fifty (50)
years if the same is constituted in favor of a town, corporation, or
association.
The purpose of this limitation is to avoid a situation where the usufruct would
become a perpetual one.”
 Since the designation is limited, it does not run counter to Art. 870 of the Civil
Code relied upon by Vda. de Aranas.

 Be it noted that Vicente Aranas is not prohibited to dispose of the fruits and
other benefits arising from the usufruct.

 Neither are the owner of the naked title(the other heirs) of the properties are
prohibited from disposing the said properties without prejudice of course to
Vicente's continuing usufruct.

 Therefore, there is no violation of Article 870 of the Civil Code since the subject
properties can be alienated anytime.

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