Русско-англо-русский юридический словарь

In civil-law countries (e.g., Germany, Japan) legacy and legatee have somewhat different meanings than in Anglo-American law. In Roman law, upon the death of a person, the totality of his legal rights and duties passed to a universal successor, the heir. If there was no valid testament, the heir was determined by the rules of intestate succession. An heir, however, could also be instituted by testament, and in his testament the testator could charge his heir with legacies—that is, duties to a third party, called a legatee, to whom the heir had to pay certain sums of money or give certain assets of the estate. (Britannica)

An heir, however, could also be instituted by testament, and in his testament the testator could charge his heir with legacies—that is, duties to a third party, called a legatee, to whom the heir had to pay certain sums of money or give certain assets of the estate. (Britannica)

In civil-law countries (e.g., Germany, Japan) legacy and legatee have somewhat different meanings than in Anglo-American law. In Roman law, upon the death of a person, the totality of his legal rights and duties passed to a universal successor, the heir. If there was no valid testament, the heir was determined by the rules of intestate succession. An heir, however, could also be instituted by testament, and in his testament the testator could charge his heir with legacies—that is, duties to a third party, called a legatee, to whom the heir had to pay certain sums of money or give certain assets of the estate. (Britannica)

Legacies could be per vindicationem ("by claim"), where the legatee became owner of the property in question, or per damnationem ("by obligation"), where the heir was required to make a regular payment to the legatee from the property. A legacy was only valid if the phrase "to whom I give and legate" (cui do lego). (Wikipedia)