Case Digest (G.R. No. 208912) Core Legal Reasoning Model
Core Legal Reasoning Model
# Facts
On May 7, 2003, Rodolfo C. Aquino filed a petition before the Regional Trial Court (RTC) of Davao City for letters of administration over the intestate estate of his father, Miguel T. Aquino (“Miguel”), who died on July 5, 1999. Miguel’s surviving heirs included his second wife, two legitimate sons (Rodolfo and Abdulah), and the heirs of his other deceased legitimate son. He was also predeceased by his first wife, Amadea C. Aquino, and two sons, including Arturo C. Aquino (“Arturo”), who died on January 10, 1978.
On July 2, 2003, Amadea Angela K. Aquino (“Angela”) moved in the same RTC probate case that she be included in the distribution of Miguel’s estate, claiming to be the illegitimate daughter of Arturo. She alleged that: her parents were never married but had no impediment to marry; her grandfather Miguel supported her mother’s pregnancy and her education; she lived with the Aquino family in their ancestral home; Miguel provided her a commercial lot; and that the Aquino
... Case Digest (G.R. No. 208912) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Case Background
- Consolidated Petitions for Review on Certiorari filed as G.R. Nos. 208912 and 209018 concerning a nonmarital child’s right to inherit from her grandfather’s estate.
- Petitioner G.R. No. 208912 (Angela) claimed to be the illegitimate daughter of Arturo C. Aquino and sought inclusion in the distribution of her alleged grandfather’s estate.
- Petitioner G.R. No. 209018 (Rodolfo) assailed the CA’s denial of his certiorari petition to invalidate the RTC’s orders granting Angela’s motions.
- Trial Court Proceedings (RTC, Branch 14, Davao City)
- On May 7, 2003, Rodolfo petitioned for letters of administration over his father Miguel T. Aquino’s intestate estate.
- On July 2, 2003, Angela filed a Motion to Be Included in the Distribution and Partition of the Estate, alleging she was Arturo’s only child and thus a contingent heir of Miguel.
- She presented a July 5, 2003 hospital certification identifying Arturo as her father and her baptismal certificate naming her “Amadea Angela Aquino.”
- She alleged family acts: Miguel paid her mother’s pregnancy expenses, allowed her residence in the Aquino home, supported her education, and intended to bequeath property to her.
- Rodolfo and Abdulah C. Aquino opposed, arguing Arturo never legally recognized Angela, she lacked documentary proof, and was born over nine months after Arturo’s death.
- By Order of April 22, 2005, the RTC granted Angela’s motions, declaring her an acknowledged child of Arturo for purposes of Miguel’s estate distribution and awarding her a monthly allowance.
- Court of Appeals Rulings
- In CA-SP No. 02269-MIN (Rodolfo’s certiorari), the CA denied Rodolfo’s petition on grounds of wrong remedy, forum shopping, and res judicata (Decision Aug. 23, 2012; Resolution Aug. 1, 2013).
- In CA-CV No. 01633 (Abdulah’s appeal), the CA reversed the RTC (Decision Jan. 21, 2013; Resolution July 24, 2013), ruling:
- Angela failed to prove her filiation under Articles 172 and 175, Family Code.
- Even if filiated, Article 992 of the Civil Code barred her from inheriting ab intestato from Miguel as an illegitimate child of a legitimate child.
- Supreme Court Proceedings
- Angela filed G.R. No. 208912; Rodolfo filed G.R. No. 209018; both were consolidated by the Third Division.
- An En Banc referral was granted to resolve the proper interpretation of Article 992 and Angela’s inheritance rights.
- Oral arguments held September 3 and September 17, 2019; parties and amici curiae submitted memoranda.
Issues:
- Whether an illegitimate child of a legitimate child (grandchild) can inherit from the grandparent’s intestate estate by right of representation despite Article 992 of the Civil Code.
- Whether Angela proved her filiation to her father, Arturo C. Aquino, pursuant to Civil Code and Family Code rules.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)