Case Summary (G.R. No. 84240)
Petitioners
Olivia S. Pascual
Hermes S. Pascual
Respondents
Esperanza C. Pascual-Bautista et al. (heirs of Don Andres Pascual from his full- and half-blood brothers)
Hon. Manuel S. Padolina, Presiding Judge, RTC Br. 162, Pasig, Metro Manila
Key Dates
• October 12, 1973 – Death of Don Andres Pascual
• December 18, 1973 – Surviving spouse names Olivia and Hermes as heirs in supplemental petition for administration
• October 16, 1985 – Heirs enter into compromise agreement excluding petitioners’ claims, subject to further court determination
• December 18, 1987 – RTC denies petitioners’ motion to reiterate hereditary rights
• April 29, 1988 – Court of Appeals dismisses petitioners’ appeal
• March 25, 1992 – Supreme Court decision
Applicable Law
• 1987 Philippine Constitution (governing charter)
• Civil Code of the Philippines: Articles 902, 982, 989, 990 (succession and representation), 992 (prohibition on intestate succession between illegitimate and legitimate relatives)
• Family Code Article 176 (classification of illegitimate children)
Undisputed Facts
- Don Andres Pascual died intestate, survived by his spouse and various siblings’ descendants.
- Eligio Pascual, full-blood brother of the decedent, predeceased or was alive; his natural children Olivia and Hermes were acknowledged in the administration petition.
- A compromise agreement among other heirs expressly reserved petitioners’ rights for final court determination.
- Petitioners’ motions to assert hereditary rights before the RTC and upon reconsideration were denied.
- The Court of Appeals affirmed the RTC decision, prompting this petition for review.
Procedural History
• RTC Branch 162 granted letters of administration to the surviving spouse and, on motion, denied Olivia and Hermes’s claim to hereditary rights.
• Court of Appeals (CA-G.R. SP. No. 14010) dismissed the appeal and denied reconsideration.
• Petitioners elevated the case to the Supreme Court via petition for review on certiorari under Rule 45.
Issue
Whether Article 992 of the Civil Code excludes acknowledged natural children from inheriting intestate from the legitimate relatives of their father, thereby barring Olivia and Hermes from representing their father, Eligio, in the succession to Don Andres Pascual’s estate.
Petitioners’ Argument
Olivia and Hermes contend that “illegitimate” in Article 992 should be strictly limited to spurious children conceived during a subsisting marriage. They assert that, as acknowledged natural children, their illegitimacy does not fall within the prohibition and that Articles 902, 989, and 982 entitle them to represent Eligio.
Respondents’ Argument
The private respondents argue that Article 992’s absolute bar applies equally to all illegitimate children—natural or spurious—excluding them from intestate succession among legitimate relatives of the father or mother. They rely on the Supreme Court’s decision in Diaz v. IAC (1990) interpreting Article 992.
Legal Analysis
- Article 992 establishes an “iron curtain” prohibiting intestate succession between illegitimate children and the legitimate children or relatives of their parent, irrespective of acknowledgment.
- In Diaz v. Intermediate Appellate Court, the Court held that Article 992 applies absolutely to all illegitimate children, preventing representation of a legitimate parent’s estate by such descendants.
- Articles 902, 989, and 990 confirm that an illegitimate child’s successional rights may pass to descendants, but this transmission remains subject to th
Case Syllabus (G.R. No. 84240)
Facts of the Case
- Don Andres Pascual died intestate on October 12, 1973, without issue, legitimate or adopted.
- Surviving heirs included his spouse Adela Soldevilla de Pascual; children of his full-blood brother Wenceslao Sr.; children of his half-blood brother Pedro; acknowledged natural children of his full-blood brother Eligio (Olivia S. Pascual and Hermes S. Pascual); and the intestate estate of his half-blood brother Eleuterio.
- Adela Soldevilla de Pascual filed a petition for Letters of Administration (RTC Case No. 7554) and, by supplemental petition and affidavit, identified Olivia and Hermes as heirs.
- On October 16, 1985, all heirs except Olivia and Hermes executed a Compromise Agreement, expressly preserving Olivia’s and Hermes’s claims to continue until final court determination.
- Olivia and Hermes filed motions to reiterate hereditary rights which the Regional Trial Court denied on December 18, 1987; their motion for reconsideration was likewise denied on January 13, 1988.
Procedural History
- Petitioners appealed the RTC’s denial to the Court of Appeals as CA-G.R. SP No. 14010.
- On April 29, 1988, the Court of Appeals dismissed the petition and on July 14, 1988 denied the motion for reconsideration.
- Petitioners filed a petition for review on certiorari with the Supreme Court, invoking Rule 45.
Issue Presented
- Whether Article 992 of the Civil Code, which bars inheritance between illegitimate and legitimate relatives, applies to acknowledged natural children and thereby excludes petitioners from representing their father in inheriting from Don