Manuel v. Ferrer
G.R. No. 117246, August 21, 1995
FACTS:
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. He would later buy two parcels and register the same under 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 over a one-half (1/2) portion of his land. Juan Manuel died intestate on 21 February 1990. Two years later, or 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 (1/2) portion of the land that was sold to the latter by Juan Manuel under the 1980 Deed of Sale Con Pacto de Retro. These acts of Modesta apparently did not sit well with petitioners. In a complaint filed before the Regional Trial Court, the petitioners sought the declaration of nullity of the instruments.
ISSUE:
Whether or not petitioners had the legal personality to contest the actions of Modesta.
RULING:
No. Petitioners, not being the real “parties-in-interest” in the case, had neither the standing nor the cause of action to initiate the complaint.
Although inn her answer to the complaint, Modesta admitted that she was not an intestate heir of Juan Manuel because she was adopted without the benefit of formal or judicial adoption and therefore was neither a compulsory nor a legal heir, the court still reiterated the following rules:
a. where the illegitimate child had half-brothers who were legitimate, the latter had no right to the former’s inheritance
b. the legitimate collateral relatives of the mother cannot succeed from her illegitimate child
c. a natural child cannot represent his natural father in the succession to the estate of the legitimate grandparent
d. the natural daughter cannot succeed to the estate of her deceased uncle who is a legitimate brother of her natural father
e. an illegitimate child has no right to inherit ab intestato from the legitimate children and relatives of his father
