G.R. No. L-41819 - People vs. Manlapaz y Poling

Petitioners are Anselma Diaz (guardian of Victor, Rodrigo, Anselmina, and Miguel Santero) and Felixberta Pacursa (guardian of Federico Santero), all natural (illegitimate) children of Pablo Santero.
Respondent is Felisa Pamuti Jardin, niece of Simona Pamuti Vda. de Santero.

Simona Pamuti Vda. de Santero was the widow of Pascual Santero and mother of Pablo Santero.
Pablo Santero was their only legitimate son and died survived by six illegitimate minor children with two women: four with Anselma Diaz and two with Felixberta Pacursa.
Felisa Pamuti Jardin and her mother Juliana were the only legitimate children of the spouses Felipe Pamuti and Petronila Asuncion. Juliana married Simon Jardin, with Felisa as their legitimate child.

Pascual Santero died in 1970; Pablo Santero died in 1973; Simona Santero died in 1976.
The dispute centers on who are the lawful heirs of the intestate estate of Simona Pamuti Vda. de Santero — Felisa Pamuti Jardin (niece) or Pablo Santero’s natural children (petitioners) through right of representation.

Whether the term “relatives” in Article 992 of the New Civil Code includes legitimate parents (or grandparents) of the illegitimate children’s father or mother, thus allowing the illegitimate grandchildren to inherit from their legitimate grandparent by right of representation.

The Intermediate Appellate Court declared Felisa Pamuti Jardin sole legitimate heir to Simona’s estate.
The decision was affirmed by the Second Division of the Supreme Court on June 17, 1987.
Petitioners filed motions for reconsideration, culminating in this second motion for reconsideration.
Oral arguments were heard en banc on November 17, 1988.
Amici curiae invited to argue included prominent jurists such as Justice Jose B.L. Reyes, former Justice Ricardo C. Puno, Dr. Arturo Tolentino, former Justice Eduardo Caguioa, and Prof. Ruben Balane.

Does the term “relatives” in Article 992 of the New Civil Code, which bars illegitimate children from inheriting ab intestato from the legitimate children or relatives of their father or mother, include the legitimate parents (or grandparents) of such illegitimate children’s father or mother?

Whether illegitimate grandchildren of a legitimate child can inherit from their legitimate grandparent by right of representation despite Article 992’s prohibition.
Whether the amendments in the New Civil Code, particularly Articles 902, 982, 989, and 990, conferred new successional rights allowing such inheritance rights to illegitimate descendants of legitimate children.