Case Digest (G.R. No. 84240) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 84240, decided on March 25, 1992 under the 1987 Constitution, petitioners Olivia S. Pascual and Hermes S. Pascual, acknowledged natural children of the late Eligio Pascual, sought to be recognized as heirs of their uncle, Don Andres Pascual. Don Andres died intestate on October 12, 1973, survived by his widow Adela Soldevilla de Pascual, the legitimate children of his full-blood brother Wenceslao Pascual, Sr., the children of his half-blood brother Pedro Pascual, and the intestate estate representatives of another half-blood brother Eleuterio T. Pascual. Adela filed a Special Proceeding (RTC, Br. 162, Rizal, SP No. 7554) for Letters of Administration, expressly naming Olivia and Hermes as heirs. On October 16, 1985, all other heirs executed a Compromise Agreement excluding petitioners’ claims, notwithstanding a proviso preserving their rights. Olivia and Hermes filed motions to reiterate hereditary rights, which the RTC (Judge Manuel S. Padolina) denied on December 1 Case Digest (G.R. No. 84240) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Petitioners Olivia S. Pascual and Hermes S. Pascual are acknowledged natural (illegitimate) children of the late Eligio Pascual.
- Respondents include:
- Esperanza C. Pascual-Bautista, Manuel C. Pascual, Jose C. Pascual, Susana C. Pascual-Bautista, Erlinda C. Pascual, Wenceslao C. Pascual, Jr. (children of Wenceslao Sr., full-blood brother of decedent)
- Avelino Pascual, Isoceles Pascual, Loida Pascual-Martinez, Virginia Pascual-Ner, Nona Pascual-Fernando, Octavio Pascual, Geranaia Pascual-Dubert (children of Pedro, half-blood brother)
- Intestate estate of Eleuterio T. Pascual (half-blood brother), represented by Dominga M. Pascual, Mamerta P. Fugoso, Abraham S. Sarmiento III, Regina Sarmiento-Macaibay, Eleuterio P. Sarmiento, Dominga P. San Diego, Nelia P. Marquez, Silvestre M. Pascual, Eleuterio M. Pascual
- The Hon. Judge Manuel S. Padolina of RTC Branch 162, Pasig
- Chronology of Proceedings and Facts
- October 12, 1973: Don Andres Pascual dies intestate without issue or adopted/spurious children; survived by:
- Surviving spouse Adela Soldevilla de Pascual
- Full-blood and half-blood siblings and their issue, including Olivia and Hermes as acknowledged natural children of Eligio
- December 18, 1973: Surviving spouse files supplemental petition for letters of administration, explicitly recognizing Olivia and Hermes as heirs; corroborates Eligio’s full-blood relation by affidavit
- October 16, 1985: All heirs except Olivia and Hermes execute a Compromise Agreement settling estate distribution, with paragraph V preserving Olivia’s and Hermes’s hereditary claims
- September 30, 1987–December 18, 1987: Olivia and Hermes file Motion to Reiterate Hereditary Rights and supporting memorandum; RTC (Judge Padolina) denies motion; MR also denied on January 13, 1988
- Appeal filed in the Court of Appeals as CA-G.R. SP No. 14010; April 29, 1988 CA decision dismisses petition; MR denied July 14, 1988
- Petition for review on certiorari filed with the Supreme Court, challenging the exclusion of acknowledged natural children under Civil Code Art. 992
Issues:
- Inheritance Rights of Acknowledged Natural Children
- Whether Article 992 of the Civil Code, which bars “illegitimate” children from inheriting ab intestato from legitimate relatives of their parent, applies to acknowledged natural children.
- Whether the doctrine of Diaz v. IAC (150 SCRA 645 [1987]) barring intestate succession between illegitimate and legitimate family lines should be extended to acknowledged natural children.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)