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)