Amadea Angela K. Aquino v. Rodolfo C. Aquino

Summary

The Supreme Court addressed the constitutional interpretation of Article 992 of the Civil Code regarding nonmarital children's inheritance rights. Angela Aquino, claiming to be the nonmarital child of Arturo Aquino (son of deceased Miguel Aquino), sought to inherit from her grandfather's estate by right of representation. The Court reinterpreted Article 992, holding that while it bars reciprocal inheritance between nonmarital children and collateral relatives of their parents, it should not prevent inheritance between nonmarital children and their direct ascendants (grandparents). The decision emphasized children's best interests and constitutional protections, noting that Article 992's original presumption of family hostility doesn't account for modern family dynamics. The case was remanded to determine Angela's filiation through evidence including potential DNA testing, establishing a more liberal approach to nonmarital children's inheritance rights while maintaining the need to prove legitimate filiation.