G.R. No. 117246, 21 August 1995, 247 SCRA 476
The petitioners in this case were the legitimate children of spouses Antonio Manuel and Beatriz Guiling. During his marriage with Beatriz, Antonio had an extra-marital affair with Ursula Bautista, from which Juan Manuel was born. Juan Manuel, the illegitimate son of Antonio, married Esperanza Gamba. In consideration of the marriage, a donation propter nuptias over a parcel of land was registered in his name. Two other parcels of land, were later bought by Juan and registered in his name. The couple were not blessed with a child of their own. Their desire to have one impelled the spouses to take private respondent Modesta Manuel-Baltazar into their fold and so raised her as their own “ daughter “.
On 03 June 1980, Juan Manuel executed in favor of Estanislao Manuel a Deed of Sale Con Pacto de Retro. Juan Manuel died intestate on 21 February 1990. Two years later, on 04 February 1992, Esperanza Gamba also passed away.
On 05 March 1992, a month after the death of Esperanza, Modesta executed an Affidavit of Self-Adjudication claiming for herself the three parcels of land. Modesta executed in favor of her co-respondent Estanislao Manuel a Deed of Renunciation and Quitclaim over the unredeemed one-half portion of land. This act of Modesta apparently did not sit well with the petitioners. The petitioners sought for the declaration of nullity of the aforesaid instruments.
WON the petitioners (legitimate children of spouses Antonio Manuel & Beatriz Guiling) are the legal heirs over one – half of Juan Manuel’s intestate estate.
Article 992 of the New Civil Code… prohibits absolutely a succession ab intestato between the illegitimate child and the legitimate children and the relatives of the father of mother of said legitimate child. They may have a natural tie of blood, but this is not recognized by law for the purpose of Article 992. Between legitimate family and the illegitimate family there is presumed to be an intervening antagonism and incompatibility. The illegitimate child is disgracefully looked down upon by the legitimate family; the legitimate family, is in turn, hated by the illegitimate child; the latter considers the privileged condition of the former, and the resources of which it is thereby deprived; the former, in turn, sees in the illegitimate child nothing but the product of sin, palpable evidence of a blemish broken in life; the law does no more than recognized this truth, by avoiding further grounds of resentment.
Furthermore, the complaint of the petitioners seeking the nullity of the Affidavit of Self-Adjudication executed by Modesta issued to her favor, as well as the Deed of Renunciation and Quitclaim in favor of Estanislao Manuel, was properly dismissed by the trial court. Petitioners not being the real party-in-interest. In the case, had neither the standing nor the cause of action to initiate the complaint.
*Case digest by AG Himang, LLB-IV, Andres Bonifacio College Law School, SY 2018-2019