Article 992 of the New Civil Code enunciates what is so commonly referred to in the

rules on succession as the "principle of absolute separation between the legitimate

family and the illegitimate family." The doctrine rejects succession ab intestato in the
collateral line between legitimate relatives, on the one hand, and illegitimate
relatives, on other hand, although it does not totally disavow such succession in the
direct line.
This rule has consistently been applied by the Supreme Court in several other cases.
Thus, it has ruled that where the illegitimate child had half-brothers who were
legitimate, the latter had no right to the former's inheritance; that the legitimate
collateral relatives of the mother cannot succeed from her illegitimate child; that a
natural child cannot represent his natural father in the succession to the estate of the
legitimate grandparent; that the natural daughter cannot succeed to the estate of
her deceased uncle who is a legitimate brother of her natural father; and that an
illegitimate child has no right to inherit ab intestato from the legitimate children and
relatives of his father (Manuel v. Ferrer, G.R. No. 117246 August 21, 1995).
The determining factor is the legitimacy or illegitimacy of the person to be
represented. If the person to be represented is an illegitimate child, then his
descendants, whether legitimate or illegitimate, may represent him; however, if the
person to be represented is legitimate, his illegitimate descendants cannot represent
him because the law provides that only his legitimate descendants may exercise the
right of representation by reason of the barrier imposed Article 992 (Diaz vs. IAC,
G.R. No. L-66574, February 21, 1990; Intestate Estate of Aguinaldo-Suntay vs.
Cojuangco-Suntay, G.R.No. 183053, June 16, 2010).