G.R. No. 208912/G.R. No. 209018, December 7, 2021
AMADEA ANGELA K. AQUINO, PETITIONER, VS. RODOLFO C. AQUINO AND ABBULAH C. AQUINO, RESPONDENTS. [G.R. No. 209018] RODOLFO C. AQUINO, PETITIONER, VS. AMADEA ANGELA K. AQUINO RESPONDENT.

FACTS

On May 7, 2003, Rodolfo C. Aquino (Rodolfo) filed a petition for letters of administration over the intestate estate of his father, Miguel T. Aquino (Miguel). Miguel was survived by his second wife, his sons Rodolfo and Abdulah C. Aquino (Abdulah) from his first marriage to Amadea C. Aquino, and the heirs of his predeceased son Wilfredo. Another son from the first marriage, Arturo C. Aquino (Arturo), also predeceased Miguel. On July 2, 2003, Amadea Angela K. Aquino (Angela) moved to be included in the distribution of Miguel’s estate, claiming to be the only child of Arturo. She was born on October 9, 1978, after Arturo’s death on January 10, 1978. Her parents were not married. Angela presented evidence of her filiation, including a hospital certification, baptismal certificate, and alleged continuous recognition by the Aquino family, including support from Miguel. Rodolfo opposed, arguing Angela was not legally recognized by Arturo and was born more than nine months after his death. The Regional Trial Court granted Angela’s motions, declaring her an acknowledged natural child of Arturo for purposes of representing him in Miguel’s estate and ordering a monthly allowance. Rodolfo and Abdulah separately challenged this order. The Court of Appeals, in a decision on Abdulah’s appeal, reversed the trial court, disqualifying Angela from inheriting from Miguel due to failure to prove filiation and, alternatively, citing Article 992 of the Civil Code which it interpreted to bar nonmarital children from inheriting from the marital relatives of their parents. Rodolfo’s separate petition for certiorari was denied by the Court of Appeals on procedural grounds. Both Angela and Rodolfo filed Petitions for Review before the Supreme Court, which were consolidated.

ISSUE

The primary issue is whether a nonmarital child (Angela) can inherit by right of representation from the intestate estate of her grandfather (Miguel), the parent of her father (Arturo), despite her father being a marital child and her parents not being married to each other.

RULING

The Supreme Court granted Angela’s petition and denied Rodolfo’s petition. The Court held that a child whose parents did not marry each other can inherit from their grandparent by right of representation, regardless of the grandparent’s marital status at the birth of the child’s parent. The Court abandoned the interpretation of Article 992 of the Civil Code that created a barrier to succession between nonmarital children and the marital relatives of their parents. It ruled that Article 992 must be read in conjunction with Articles 902, 972, 974, 980, and 981 of the Civil Code, which establish the right of representation in succession. The right of representation applies regardless of whether the representative (Angela) is a marital or nonmarital child, and regardless of whether the person represented (Arturo) is a marital or nonmarital child. The Court emphasized that the right of representation is a fiction of law where the representative steps into the shoes of the person represented. Therefore, Angela, as the legitimate child of Arturo (a marital child), inherits from Miguel in the same place and degree as her father Arturo would have, had he not predeceased Miguel. The Court also found that Angela had sufficiently proven her filiation as Arturo’s nonmarital child through the evidence she presented. The Court of Appeals’ decision disqualifying Angela was reversed and set aside.