from the succession, as were relatives in the female line (i.e. relatives of the deceased's mother), and the deceased's spouse. This system was altered by the law of the praetor, so that all children, including emancipated children, inherited in first instance, then agnate relatives in the male line, then relatives in the male or female line based according to six degrees of proximity, and finally the widow of the deceased (excluded because she was assumed to form part of her father's inheritance, not her husband's). If any of these people had already received a portion of the estate during the lifetime of the deceased (e.g. as a dowry), that amount would be subtracted from their share of the estate. Mothers of at least three children were given a right to inherit from their children by the senatus consultum Tertullianum. Legitimate and illegitimate children were made the presumed heirs of their mothers by the senatus consultum Orfitianum. In Late Antiquity, Justinian abolished this system in two rulings delivered in AD 543 and 548, in favour of a system where property of the deceased went to the descendants in first instance, then to ascendants and siblings, and then to more distant relatives, with no distinction between the male and female line and no right to succession on the part of the widow. Testamentary succession Most Roman inheritances were not intestate. Instead, they were governed by a will (testamentum). Some Roman writers speak of producing a will as a duty (officium). Henry Maine in 1861 characterised the Roman approach as a "horror of intestacy." Only a pater familias (male head of household) could make a will that disposed of a whole estate. But any Roman citizen who had reached the age of majority could make a will for property that they possessed in their own right. Women could make wills through a process of fictional sale (coemptio), until the reign of Hadrian, when they were given the ability to make a will through their tutor (legal guardian). Non-Romans (peregrini) and people with intellectual disabilities could not make wills under Roman law. Exiles were not allowed to make wills either and this ban was retrospective; being sent into exile voided any will that the exile had already made. The will had to name an heir. In addition to this, it could name a legal guardian (tutor) for underage children, manumit slaves, and leave legacies