### Facts:
The case revolves around the execution and probate of a joint will by spouses Bernabe de la Cerna and Gervasia Rebaca in 1939, favoring their niece Manuela Rebaca Potot due to their childlessness. Bernabe died in the same year, and the will entered probate successfully without opposition. In 1952, upon Gervasia’s death, another probate process was initiated but was dismissed due to the non-appearance of the petitioners.
Paula de la Cerna and others, as intestate heirs of Bernabe, contested the will’s validity, arguing against the legality of joint wills based on the Civil Code provisions. The Court of First Instance of Cebu initially declared the will null and void. However, the Court of Appeals reversed this decision, affirming the probate decree’s finality from 1939 and consequently dismissing the action for partition initiated by Paula de la Cerna and others.
### Issues:
1. Whether the joint will of Bernabe de la Cerna and Gervasia Rebaca is valid despite the prohibition against joint wills as per the Civil Code.
2. Whether the final decree of probate from 1939 can be challenged for contravening the Civil Code provisions.
3. The extent to which the final probate decree affects the disposition of Gervasia Rebaca’s share of the conjugal properties.
### Court’s Decision:
The Supreme Court held that the probate decree of 1939 is conclusive and binding upon the world, including on matters of the will’s validity despite the general prohibition against joint wills. The Court further emphasized that errors in law committed by the probate court, such as admitting a joint will, do not affect its jurisdiction or the finality of its decisions. However, the Court clarified that the probate decree had authority solely over Bernabe de la Cerna’s estate and not over Gervasia Rebaca’s share, whose disposition must be reexamined upon her death.
### Doctrine:
The Supreme Court, upholding the Civil Code provisions, reiterated the prohibition against joint wills. Nonetheless, it recognized the principle that a final judgment in a probate proceeding is conclusive and binding upon the world. The Court further established that errors in legal judgment by the probate court do not invalidate its jurisdiction or the finality of its decisions.
### Class Notes:
– **Prohibition of Joint Wills:** Civil Code provisions explicitly prohibit the drafting of joint wills, whether for reciprocal benefits or for a third party’s benefit.
– **Finality of Probate Decrees:** A probate decree is conclusive and binding upon the world, making its decisions final and unchallengeable, barring errors affecting jurisdiction.
– **Jurisdiction Over Unprobated Shares:** The probate court’s jurisdiction extends only to the estates of deceased individuals. Thus, properties or interests solely belonging to surviving parties are not covered by a deceased’s probate decree.
– **Legal Error vs. Jurisdiction:** Errors in interpretation or application of law by a probate court do not compromise the validity of its final decisions.
### Historical Background:
This case highlights the practice and legal interpretations concerning wills and inheritance in the Philippines post-1930s, specifically within the framework of the then-operative Civil Code provisions against joint wills. It underscores the judiciary’s role in finalizing estate distributions and the immutability of probate decree judgments, alongside reflecting on traditional testamentary practices vis-à-vis statutory mandates.
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