G.R. No. 66574 February 21, 1990
ANSELMA DIAZ, guardian of VICTOR, RODRIGO, ANSELMINA and MIGUEL, all surnamed SANTERO, and FELIXBERTA PACURSA, guardian of FEDERICO SANTERO, et al., petitioners, vs. INTERMEDIATE APPELLATE COURT and FELISA PAMUTI JARDIN, respondents.

FACTS

The case involves the intestate estate of Simona Pamuti Vda. de Santero. Simona died survived by her niece, respondent Felisa Pamuti-Jardin, and by six illegitimate grandchildren—the natural children of Simona’s only legitimate son, Pablo Santero, who predeceased her. Petitioners, as guardians of these illegitimate grandchildren, claim the right to inherit from Simona by representing their father Pablo. Respondent Felisa, as Simona’s legitimate niece, asserts she is the sole heir.
The core dispute is whether the illegitimate children of Pablo, a legitimate child, can represent him in inheriting from their legitimate grandmother, Simona. This hinges on the interpretation of Article 992 of the Civil Code, which states: “An illegitimate child has no right to inherit ab intestato from the legitimate children or relatives of his father or mother; nor shall such children or relatives inherit in the same manner from the illegitimate child.” The specific question is whether the term “relatives” in this article includes the legitimate parent (the grandparent) of the illegitimate children’s father.

ISSUE

Do the illegitimate children of a legitimate child have the right to represent their father in the intestate succession of their legitimate grandparent, or are they absolutely barred by Article 992 of the Civil Code?

RULING

The Supreme Court, in its Resolution, denied the petitioners’ second motion for reconsideration and upheld the barrier established by Article 992. The illegitimate grandchildren cannot inherit from their legitimate grandmother, Simona Pamuti Vda. de Santero.
The legal logic is anchored on a strict interpretation of Article 992, which creates an absolute barrier to intestate succession between the illegitimate and legitimate families. The Court clarified that the term “relatives” in Article 992 encompasses all legitimate kindred of the father or mother, including ascendants like grandparents. Therefore, an illegitimate child is prohibited from inheriting ab intestato not only from the legitimate brothers and sisters of their parent but also from the legitimate parents (grandparents) of their parent.
The Court rejected the argument that the general rule on representation under Article 982 (“grandchildren and other descendants shall inherit by right of representation”) applies. It ruled that Article 992 is a specific exception that prevails. While the New Civil Code granted new successional rights to illegitimate children (e.g., Articles 902, 989, and 990 allow representation among illegitimate descendants), these provisions apply only where the person being represented is themselves illegitimate. The right of representation is not extended to illegitimate descendants seeking to inherit from a legitimate ascendant. To allow otherwise would nullify the express prohibition in Article 992. Consequently, Felisa Pamuti-Jardin, as the sole legitimate relative within the prohibited degree, is the exclusive heir to Simona’s estate.