Prior Declaration of Heirship in Ordinary Civil Action to Protect or Enforce Hereditary Rights: An Analysis of Treyes v. Larlar
Summary In the recent en banc case of Treyes v. Larlar, G.R. No. 232579, 8 September 2020, the Supreme Court declared that “the rule laid down in [Ypon v. Ricaforte, 700 SCRA 778 (2013)], Yaptinchay, Portugal …and other similar cases, which requires a prior determination of heirship in a separate special proceeding as a prerequisite…