Benigno Manuel v. Hon. Nicodemo T. Ferrer

Summary

Legitimate siblings challenged the self-adjudication of property by Modesta, the informal adopted daughter of their deceased illegitimate brother Juan Manuel who died intestate. The Supreme Court affirmed dismissal of their complaint, ruling that Article 992 of the Civil Code creates an absolute barrier preventing intestate succession between legitimate and illegitimate family members. While acknowledging that Modesta, as an informal ward without judicial adoption, had no legal right to inherit, the Court held that the legitimate siblings lacked standing as real parties-in-interest since they could not inherit from their illegitimate brother under the principle of absolute separation between legitimate and illegitimate families in succession law.