Short answer. Only if the testator expressly said so in the will. Article 949 of the Civil Code provides that for a generic or quantitative bequest, income and interest from the date of death pass to you only when the testator has expressly so ordered. If the will is silent, the income does not automatically flow to you from death.
What the law says
If the bequest should not be of a specific and determinate thing, but is generic or of quantity, its fruits and interests from the time of the death of the testator shall pertain to the legatee or devisee if the testator has expressly so ordered.
Civil Code, Article 949 — Non-Specific Bequests. Read the full provision →
The difference between specific and generic bequests
A bequest can be specific — "I leave my 2019 Toyota Fortuner with plate number ABC 123 to my nephew" — or generic, meaning it refers to a class or quantity rather than a particular identified thing: "I leave one million pesos to my nephew" or "I leave fifty shares of stock to my sister." Article 949 governs the generic case. Because the exact asset is not identified until the estate is settled and delivery is made, the question arises: does the legatee get the income earned on that amount from the date of death, or only from the date of actual delivery?
The answer depends on what the will says
For a generic bequest, income and interest from the time of death belong to the legatee only if the testator expressly ordered it. This is a deliberate rule: because the specific asset has not been identified, it is not obvious what is generating income on the legatee's behalf during the settlement period. The estate may hold various assets, and the income from the estate generally benefits the estate as a whole during administration. If the testator wants the legatee to share in that income from the moment of death, they need to say so clearly in the will.
If the will is silent
When the will does not address income on a generic bequest, the legatee is not entitled to fruits and interest earned before delivery. They receive the principal amount or generic thing bequeathed to them — not the income that accumulated during the estate proceedings. This is the default rule. It means that if settlement takes a long time, the legatee may lose out on interest that built up during that period, unless the testator thought ahead and included a provision directing that income be added.
What this means when reading a will
If you are a legatee of a generic bequest and you want to know whether you are owed income from the date of death, look carefully at the will's exact language. A phrase like "together with all income earned thereon from the date of my death" or "including all interests accruing from my death" would satisfy the express-order requirement. Vague or aspirational language probably will not. If the will is ambiguous, you may need proper legal advice on how to interpret the specific provision — this is not a question Article 949 answers on its own.