half the inheritance. Manumissions Originally, the testator was able to manumit any number of slaves in the will. Under Augustus, the Lex Fufia Caninia of 2 BC placed an absolute maximum limit of one hundred manumissions and lower limits for estates which had smaller numbers of slaves. The motivation for this may have been a desire to limit the number of freedmen and/or to prevent the testator from bankrupting the estate. Somewhere between 5% and 8% of all Roman manumissions were testamentary manumissions. Legacies The testator could leave legacies to third parties, which the heir was obliged to pay from the estate. Legacies could provide a method for leaving property to people who could not legally be heir, but foreigners, communities, and uncertain persons could not be legatees either. Unlike the heir, legatees were not liable for the estates debts. 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). Legacies could include dowries, money given to slaves (peculium), furniture, wine, and so on. Annuities might be granted to servants of the deceased, to be paid on a certain day each year for the rest of the servant's life. A lifetime usufruct of a property was often granted to the widow of the deceased. Legacies were often used to leave money to towns or associations for specific purposes (e.g., holding games in honour of the deceased, constructing public buildings, providing heating for the bathhouse or oil for the gymnasium. Under the Lex Falcidia of 40 BC, legacies could not take up more than three-quarters of the total estate (i.e. the heirs had to receive at least a quarter). If the legacies were more than this amount, then they would be reduced in order to ensure that the heirs received a quarter of the total value of the estate. Justinian merged legacies into the system of fideicommissa discussed below. Challenging the will Under the Twelve Tables, testators had complete freedom of testation. In the Late Republic, children could file a "complaint of the undutiful will" (querela inofficiosi testamenti) before the centumviral court, if the will gave them less than one quarter of what they would have