Republic Flour Mills vs Commissioner of Customs

39 SCRA 269

FACTS
The personalities involved: (1) Republic Flour Mills (petitioner) is a domestic
corporation engaged in the manufacture of wheat flour and in the process of
milling said product, produces pollard (darak) and bran (ipa); (2) Respondents
are the Commisioner of Customs and the Court of Tax Appeals.

The complaint: Petitioner questions respondents decision to charge the

corporation P7,948 in wharfage dues on exported pollard and/or bran.
Petitioner paid this amount in protest. Petitioner sent the case to Court of Tax
Appeals who decided in favour of respondent (sustained the actions of the
Commissioner of Customs). Petitioner elevated the matter to the SC and
requested that the decision of the Court of Tax Appeals be reviewed.

Petitioner claims: Section 2802 of the Tariff Custom Code (which was
respondents basis for the collection of wharfage dues) is not applicable in the
case at bar because the bran and pollard are actually not "products of the
Philippines" because they came from wheat grain which were imported from
abroad.

ISSUES
Is respondent liable for wharfage dues on its exportation of bran and pollard
as they are not "products of the Philippines?

HELD
The SC denied the petition; It re-affirmed the Court of Tax Appeals decision.

Rationale: The petitioner erred in its construction of the Act. As per section
2802 of the Tariff and Custom Code, "There shall be levied, collected and
paid on all articles imported or brought into the Philippines, and on products of
 the Philippines exported from the Philippines, a charge of two pesos per gross
metric ton as a fee for wharfage. The meaning and intent of the Act is
precisely to collect tariffs on anything imported and exported to and from the

Philippines. General words construed generally

Generalia verba sunt generaliter intelligenda - what is generally spoken shall be generally understood;
general words shall be understood in a general sense.
Generale dictum generaliter est interpretandum - a general statement is understood in a general sense
In case word in statute has both restricted and general meaning, GENERAL must prevail; Unless nature
of the subject matter & context in which it is employed clearly indicates that the limited sense is intended.

Republic Flour Mills v. Commissioner of Customs

product of the Philippines any product produced in the country, e.g. bran (ipa) & pollard (darak)
produced from wheat imported into the country are products of the Philippines

Generic term includes things that arise thereafter

Progressive interpretation - A word of general signification employed in a statute, in absence of
legislative intent, to comprehend not only peculiar conditions obtaining at its time of enactment but those
that may normally arise after its approval as well
Rationale: to keep statute from becoming ephemeral (short-lived) and transitory (not permanent or
lasting).
General rule in StatCon: Legislative enactments in general comprehensive operation, apply to persons,
subjects and businesses within their general purview and scope coming into existence subsequent to their
passage.

National Federation of Labor (NFL) v. Eisma

GR L-61236, 31 January 1984 (127 SCRA 419)En Banc, Fernando (p): 9 concur, 1 concur with comments,
1 took no part, 1 on leave
Facts:
On 5 March 1982, the National Federation of Labor filed with the Ministry of Labor andEmployment
(Labor Relations Division, Zamboanga City), a petition for direct certification asthe sole exclusive
collective bargaining representative of the monthly paid employees at theLumbayao manufacturing
plant of the Zamboanga Wood Products, Inc. (Zambowood). On 17April 1982, such employees charged
the firm before the same office for underpayment of monthly living allowances. On 3 May 1982, the
union issued a notice of strike against the firm,alleging illegal termination of Dionisio Estioca, president
of the said local union; unfair labor practice; nonpayment of living allowances; and employment
of oppressive alien management personnel without proper permit. The strike began on 23 May 1982.On
9 July 1982, Zambowood filed a complaint with the trial court against the officers andmembers of the
union, for damages for obstruction of private property with prayer for preliminary injunction and/or
restraining order. The union filed a motion for the dismissal andfor the dissolution of the restraining
order, and opposition to the issuance of the writ of preliminary injunction, contending that the
incidents of picketing are within the exclusive jurisdiction of the Labor Arbiter pursuant to Batas
Pambansa 227 (Labor Code, Article 217) andnot to the Court of First Instance. The motion was denied.
Hence, the petition for certiorari.
Issue:
Whether construction of the law is required to determine jurisdiction.
Held:
The first and fundamental duty of courts is to apply the law. Construction andinterpretation come only
after it has been demonstrated that application is impossible or inadequate without them.Jurisdiction
over the subject matter in a judicial proceeding is conferred by the sovereignauthority which organizes
the court; and it is given only by law. Jurisdiction is never presumed;it must be conferred by law in
words that do not admit of doubt. Since the jurisdiction of courtsand judicial tribunals is derived
exclusively from the statutes of the forum, the issue should beresolved on the basis of the law or statute
in force. Therefore, since (1) the original wording of Article 217 vested the labor arbiters with
jurisdiction; since (2) Presidential Decree 1691reverted the jurisdiction with respect to money claims of
workers or claims for damages arisingfrom employer-employee relations to the labor arbiters after
Presidential Decree 1367 transferredsuch jurisdiction to the ordinary courts, and since (3)
Batas Pambansa 130 made no change withrespect to the original and exclusive jurisdiction of Labor
Arbiters with respect to money claimsof workers or claims for damages arising from employer-employee
relations; Article 217 is to beapplied the way it is worded. The exclusive original jurisdiction of a labor
arbiter is therein provided for explicitly. It means, it can only mean, that a court of first instance judge
then, aregional trial court judge now, certainly acts beyond the scope of the authority conferred on him

by law when he entertained the suit for damages, arising from picketing that accompanied astrike.The
Supreme Court, thus, granted the writ of certiorari, and nullified and set aside the 20 July1982 order
issued by the court a quo. It granted the writ of prohibition, and enjoined the Judge of said court, or
whoever acts in his behalf in the RTC to which this case is assigned, from takingany further action on the
civil case (Civil Case 716 [2751]), except for the purpose of dismissingit. It also made permanent the
restraining order issued on 5 August 1982.
1. National Federation of Labor v. Eisma
Construction is required to determine jurisdiction.

The first and fundamental duty of courts is to apply the law. Construction and
interpretation come only after it has been demonstrated that application is impossible or
inadequate without them. However, jurisdiction over the subject matter in a judicial
proceeding is conferred by the sovereign authority, which organizes the court; and it is
given only by law. Jurisdiction is never presumed; it must be conferred by law in words
that do not admit of doubt. Since the jurisdiction of courts and judicial tribunals is derived
exclusively from the statutes of the forum, the issue should be resolved on the basis of
the law or statute in force.

KAPISANAN NG MGA MANGGAGAWA SA MANILA

RAILROADCOMPANY CREDIT UNION, INC., petitioner-
appellant, vs.MANILA RAILROAD COMPANY, respondentappellee.
FACTS:-mandamus petition dismissed by the lower court,
petitioner-appellant would seek a reversal of such decision relying onwhat it considered
to be a right granted by Section 62 of theRepublic Act No. 2023,
more specifically the first two paragraphsthereof:(1) A member of a cooperative may,
notwithstanding the provisionsof existing laws, execute an agreement in favor of the co-
operativeauthorizing his employer to deduct from the salary or wages payableto him by the
employer such amount as may be specified in theagreement and to pay the amount so
deducted to the co-operative insatisfaction of any debt or other demand owing from the member
tothe co-operative. (2) Upon the exemption of such agreement the employer shall if sorequired
by the co-operative by a request in writing and so long assuch debt or other demand or any part
of it remains unpaid, makethe claimant and remit forth with the amount so deducted to the co-
operative."
-

petitioner contends that under the above provisions of Rep.Act 2023, the loans granted
by credit union to its membersenjoy first priority in the payroll collection from
therespondent's employees' wages and salaries.
-
Court ruled in favor of respondent
and held that:there is nothing in the provision of Rep. Act 2023 hereinabovequoted which
provides that obligation of laborers and employeespayable to credit unions shall enjoy first
priority in the deduction fromthe employees' wages and salaries.The
only effect of Rep. Act 2023 is to compel the employer todeduct from the salaries or
wages payable to members of theemployees' cooperative credit unions the employees'
debts tothe union and to pay the same to the credit union.
if Rep. Act 2023 had been enacted,
the employer could not becompelled to act as the collecting agent of the
employees'credit union for the employees' debt to his credit union but tocontend that the
debt of a member of the employeescooperative credit union as having first priority in the
matter of deduction, is to write something into the law which does not

appear.
the
mandatory character of Rep. Act 2023 is only to compel theemployer to make the
deduction of the employees' debt fromthe latter's salary and turn this over to the
employees' creditunio
n but this mandatory character does not convert the creditunion's credit into a first priority
credit.If the legislative intent in enacting pars. 1 and 2 of Sec. 62 of Rep. Act 2023 were to give
first priority in the matter of payments to theobligations of employees in favor of their credit
unions, then, the lawwould have so expressly declared. Thus, the express provisions of the New
Civil Code, Arts. 2241, 2242 and 2244 show the legislativeintent on preference of credits.
ISSUE: WON the petitioners interpretation of RA 2023 is correct?
HELD: NO-that there is
nothing in said provision from which it could beimplied that it gives top priority to
obligations of the nature of that payable to petitioner, and that, therefore,
respondentcompany did not violate the above-quoted Section 62 of Republic Act 2023.
- The applicable provision of
Republic Act No. 2023 quoted earlier,speaks for itself. There is no ambiguity

RCPI vs NTC Case Digest

RADIO COMMUNICATIONS OF THE PHILIPPINES, INC. (RCPI) vs. NATIONAL
TELECOMMUNICATIONS COMMISSION (NTC) and JUAN A. ALEGRE
G.R. No. 93237 November 6, 1992

Facts: Private respondent Juan A. Alegre's wife, Dr. Jimena Alegre, sent two (2) RUSH telegrams
through petitioner RCPI's facilities in Taft Ave., Manila at 9:00 in the morning of 17 March 1989
to his sister and brother-in-law in Valencia, Bohol and another sister-in-law in Espiritu, Ilocos
Norte.

Both telegrams did not reach their destinations on the expected dates. So, private respondent
filed a letter-complaint against RCPI with National Telecommunications Commission (NTC) for
poor service, with a request for the imposition of the appropriate punitive sanction against the
company. Taking cognizance of the complaint, NTC directed RCPI to answer the complaint and
set the initial hearing.

NTC held that RCPI was administratively liable for deficient and inadequate service under Section
19(a) of C.A. 146 and imposed the penalty of fine payable within thirty (30) days from receipt in
the aggregate amount of one thousand pesos.

Hence, RCPI filed this petition for review invoking C.A. 146 Sec. 19(a) which limits the jurisdiction
of the Public Service Commission (precursor of the NTC) to the fixing of rates.

ISSUE: Whether or not Public Service Commission (precursor of the NTC) has jurisdiction to
impose fines

HELD: The decision appealed from is reversed and set aside for lack of jurisdiction of the NTC to
render it.

NTC has no jurisdiction to impose a fine. Under Section 21 of C. A. 146, as amended, the
Commission was empowered to impose an administrative fine in cases of violation of or failure
by a public service to comply with the terms and conditions of any certificate or any orders,
decisions or regulations of the Commission. Petitioner operated under a legislative franchise, so
there were no terms nor conditions of any certificate issued by the Commission to violate. Neither
was there any order, decision or regulation from the Commission applicable to petitioner that the
latter had allegedly violated, disobeyed, defied or disregarded.

No substantial change has been brought about by Executive Order No. 546 invoked by the
Solicitor General's Office to bolster NTC's jurisdiction. The Executive Order is not an explicit grant
of power to impose administrative fines on public service utilities, including telegraphic agencies,
which have failed to render adequate service to consumers. Neither has it expanded the coverage
of the supervisory and regulatory power of the agency. There appears to be no alternative but to
reiterate the settled doctrine in administrative law that:

Too basic in administrative law to need citation of jurisprudence is the rule that jurisdiction and
powers of administrative agencies, like respondent Commission, are limited to those expressly
granted or necessarily implied from those granted in the legislation creating such body; and any
order without or beyond such jurisdiction is void and ineffective (Globe Wireless case).
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Perfecto Floresca vs Philex Mining Corporation

November 6, 2010

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136 SCRA 141 Political Law Separation of Powers SC Cannot Legislate; Exception

Statutory Construction Determining the Purpose of the Law

Perfecto Floresca et al are the heirs of the deceased employees of Philex Mining Corporation
who, while working at its copper mines underground operations in Tuba, Benguet on June 28,
1967, died as a result of the cave-in that buried them in the tunnels of the mine. Theircomplaint
alleges that Philex, in violation of government rules and regulations, negligently and deliberately
failed to take the required precautions for the protection of the lives of its men working
underground. Floresca et al moved to claim their benefits pursuant to the Workmens
Compensation Act before the Workmens Compensation Commission. They also filed a separate
civil case against Philex for damages.

Philex sought the dismissal of the civil case as it insisted that Floresca et al have already claimed
benefits under the Workmens Compensation Act.

ISSUE: Whether or not Philex is correct.

HELD: Yes. Under the law, Floresca et al could only do either one. If they filed for benefits under
the WCA then they will be estopped from proceeding with a civil case before the regular courts.
Conversely, if they sued before the civil courts then they would also be estopped from claiming
benefits under the WCA.

HOWEVER, the Supreme Court ruled that Floresca et al are excused from this deficiency due to
ignorance of the fact. Had they been aware of such then they may have not availed of such a
remedy. But, if in case theyll win in the lower court whatever award may be granted, the amount
given to them under the WCA should be deducted. The SC emphasized that if they would go
strictly by the book in this case then the purpose of the law may be defeated. Idolatrous reverence
for the letter of the law sacrifices the human being. The spirit of the law insures mans survival
and ennobles him. As Shakespeare said, the letter of the law killeth but its spirit giveth life.
 Justice Gutierrez dissenting

No civil suit should prosper after claiming benefits under the WCA. If employers are already liable
to pay benefits under the WCA they should not be compelled to bear the cost of damage suits or
get insurance for that purpose. The exclusion provided by the WCA can only be properly removed
by the legislature NOT the SC.

Meaning of term dictated by context

The context in which the word or term is employed may dictate a different sense
Verba accipienda sunt secundum materiam- a word is to be understood in the context in which it is used.

Peo. v. Nazario
STATUTE: Municipal tax ordinance provides any owner or manager of fishponds shall pay an annual
tax of a fixed amount per hectare and it appears that the owner of the fishponds is the government which
leased them to a private person who operates them
Word: Owner does not include government as the ancient principle that government is immune from
taxes.

Paras v. COMELEC
G.R. No. 123169 (November 4, 1996)

FACTS: A petition for recall was filed against Paras, who is the incumbent Punong Barangay.
The recall election was deferred due to Petitioners opposition that under Sec. 74 of RA No.
7160, no recall shall take place within one year from the date of the officials assumption to
office or one year immediately preceding a regular local election. Since the Sangguniang
Kabataan (SK) election was set on the first Monday of May 2006, no recall may be instituted.

ISSUE: W/N the SK election is a local election.

HELD: No. Every part of the statute must be interpreted with reference to its context, and it
must be considered together and kept subservient to its general intent. The evident intent of
Sec. 74 is to subject an elective local official to recall once during his term, as provided in par.
(a) and par. (b). The spirit, rather than the letter of a law, determines its construction. Thus,
interpreting the phrase regular local election to include SK election will unduly circumscribe the
Code for there will never be a recall election rendering inutile the provision. In interpreting a
statute, the Court assumed that the legislature intended to enact an effective law. An
interpretation should be avoided under which a statute or provision being construed is defeated,
meaningless, inoperative or nugatory.
Alonzo vs. IAC
GR Number + Date: G.R. No. 72873 May 28, 1987Petition:
Petition for review by way of certiorari
:
Appeal from a decision of the Intermediate Appellate Court
Petitioner:
C A R L O S A L O N Z O a n d C A S I M I R A ALONZO
Respondent:
INTERMEDIATE APPELLATE COURTand TECLA PADUA
Ponencia:
Cruz, J.
DOCTRINE: Statutory Construction: LegislativeIntent
: T h e s p i r i t , r a t h e r t h a n t h e l e t t e r o f a s t a t u t e determines its construction, hence,
a statute must beread according to its spirit or intent. For what is withinthe spirit is within the
letter but although it is not withinthe letter thereof, and that which is within the letter butn o t w i t h i n
the spirit is not within the statute. Stateddifferently, a thing which is within
t h e i n t e n t o f t h e lawmaker is as much within the statute as if within theletter; and a thing
which is within the letter of the statuteis not within the statute unless within the intent of
thelawmakers.
FACTS:
1 . 5 B r o t h e r s a n d S i s t e r s i n h e r i t e d q u a l p r o indiviso shares a parcel of land registered in
'thename of their deceased parents.
2.
One of them, through an absolute deed of sale,transferred to petitioners, his undivided share of the land.

A year later, his sister sold her share ina Con Pacto de Retro Sale.3.Petitioners
occupied the two fifths of the landrepresenting the portions sold to them andthereafter enclosed it
with a fence.4 . T h e s o n o f t h e p e t i t i o n e r s , E d u a r o A l o n z o a n d his wife, then built a semi-
concrete house withthe consent of the petitioners.5 . O n e o f t h e h e i r s t o t h e l a n d s o u g h t t o
r e d e e m t h e portions that were sold but was subsequently denied due to him being an American
citizen.6 . A n o t h e r c o - h e i r , f i l e d h e r o w n c o m p l a i n t invoking the same right of redemption
claimed by her brother.7 . T h e t r i a l c o u r t a l s o d i s m i s s t h i s c o m p l a i n t , n o w on the ground
that the right had lapsed, nothaving been exercised within thirty days fromnotice of the sales. Although
there was no written notice, it was held that actual knowledgeof the sales by the co-heirs satisfied
therequirement of the law.8.IAC, in reversing the trial court, the respondentcourt declared that
the notice required by thesaid article was written notice and that actualnotice would not suffice as a
substitute.
ISSUES:
1 . W o N a c t u a l k n o w l e d g e s a t i s f i e d t h e r e q u i r e m e n t of Article 1088 of the Civil Code.
PROVISIONS: Art. 1088
. Should any of the heirs sell his hereditary rights to a stranger before the partition, any or all of theco-
heirs may be subrogated to the rights of the purchaser by reimbursing him for the price of the sale,
providedthey do so within the period of one month from the timethey were notified in writing of the sale
by the vendor.
RULING + RATIO:1 . Y e s . a.
While we admittedly may not legislate, wenevertheless have the power to interpret thelaw in such a way
as to reflect the will of thelegislature. While we may not read into
thel a w a p u r p o s e t h a t i s n o t t h e r e , w e nevertheless have the right
to read out of itthe reason for its enactment. In doing so, wedefer not to "the letter that killeth"
but to"the spirit that vivifieth," to give effect to thelaw maker's will.
b.
 Was there a valid notice? Granting that thelaw requires the notice to be written,
woulds u c h n o t i c e b e n e c e s s a r y i n t h i s c a s e ? Assuming there was a valid notice
althoughi t w a s n o t i n w r i t i n g . w o u l d t h e r e b e a n y q u e s t i o n t h a t t h e 3 0 -
d a y p e r i o d f o r r e d e m p t i o n h a d e x p i r e d l o n g b e f o r e t h e complaint was filed in
1977? In the face of the established facts, we cannot accept theprivate respondents' pretense
that they wereunaware of the sales made by their brothera n d s i s t e r i n 1 9 6 3 a n d 1 9 6 4 . B y
r e q u i r i n g written proof of such notice, we would beclosing our eyes to the obvious truth in
favoro f t h e i r p a l p a b l y f a l s e c l a i m o f i g n o r a n c e , t h u s e x a l t i n g t h e l e t t e r o f t h e
l a w o v e r i t s p u r p o s e . T h e p u r p o s e i s c l e a r e n o u g h : t o make sure that the
redemptioners are duly notified. We are satisfied that in this case
theo t h e r b r o t h e r s a n d s i s t e r s w e r e a c t u a l l y i n f o r m e d , a l t h o u g h n o t i n w r i t i n g , o f
t h e sales made in 1963 and 1964, and that suchnotice was sufficient.
c.
The co-heirs in this case were undeniably informed of the sales although no notice
in writing was given them. And there is nodoubt either that the 30-day period beganand ended
during the 14 years between
thes a l e s i n q u e s t i o n a n d t h e f i l i n g o f t h e complaint for redemption in
1977, withoutt h e c o - h e i r s e x e r c i s i n g t h e i r r i g h t o f redemption. These are the
justifications forthis exception.
DISPOSITION1.
WHEREFORE, the petition is granted. Thedecision of the respondent court is REVERSEDand that of the
trial court is reinstated, withoutany pronouncement as to costs. It is so ordered.

Case No. 11 | Midterms Case No. 2Elena Salenillas and Bernardino Salenillas vs
CA GR No. 78687, January 31, 1989Statutory Rule: Between two statutory
interpretations, that which better servesthe purpose of the law should
prevail.Facts:The parents of Elena Salenillas, one of the petitioners, were grantees
of free patent. The subject property was later sold to Elena Salenillas and
herhusband, petitioners in the instant case. On December 4, 1973, the property
of petitioners was mortgaged to Philippine National bank as security for a loan
of P2,500. For failure to pay their loan, the property was foreclose by PNB and
wasbought at a public auction by private respondent. Petitioner maintains that
theyhave a right to repurchase the property under Sec. 119 of the Public Land
Act.Respondent states that the sale of the property disqualified petitioner from
beinglegal heirs vis-a-vis the said property.Issue:W/N petitioners have the right to
repurchase the property under Sec. 119 of thePublic Land Act.Held: Yes. Sec. 119
of the Public Land Act provides that "every conveyance of land acquired under the
free patent or homestead provisions shall be subject torepurchase by the applicant,
his widow or legal heirs within a period of five yearsfrom the date or conveyance."
The provision makes no distinction between thelegal heirs. The distinction made by
respondent contravenes the very purpose of the act. Between two statutory
interpretations, that which better serves thepurpose of the law should prevail.Case
No. 12 | Midterms Case No. 3B/Gen Jose Commendador, et al. vs B/Gen Demetrio
Camera, et al.GR No. 96948, August 2, 1991Statutory rule: When the reason of the
law ceases, the law itself ceases.Facts:Petitioners are members of the Armed
Forces of the Philippines andwere charged with violations of Articles of War in
relation with their alleged
participation in a failed coup detat. Their case was referred to General Court
Martial No. 14. At a hearing, petitioners manifested their desire to exercise
theirright to raise peremptory challenges against the President and the members
of the general court martial invoking Art. 18 of CA No. 408. GCM No. 14 ruled
thatperemptory challenges had been discontinued under PD 39.Issue: W/N the right
to peremptory challenge provide by Art. 18 of CA No. 408has been discontinued
under PD 39.Held:No. Although PD 39 disallowed peremptory challenged allowed
underCA No. 408, PD 39 however was issued to implement General Order No. 8
issuedduring martial law to create military tribunals. With the lifting of Martial
Law,General Order No. 8 was revoked and military tribunals were dissolved. As
such,the reason for the existence of PD 39 ceased automatically. When the reason
of the law ceases, the law itself ceases.
Cessante ratione legis, cessat ipsa lex.

Pascual vs. pascual-Bautista

OLIVIA S. PASCUAL and HERMES S. PASCUAL, petitioners, vs.
ESPERANZA C. PASCUAL-BAUTISTA, MANUEL C. PASCUAL, JOSE C. PASCUAL, SUSANA C. PASCUAL-
BAUTISTA, ERLINDA C. PASCUAL, WENCESLAO C. PASCUAL, JR., INTESTATE ESTATE OF ELEUTERIO T.
PASCUAL, AVELINO PASCUAL, ISOCELES PASCUAL, LEIDA PASCUAL-MARTINES, VIRGINIA PASCUAL-NER,
NONA PASCUAL-FERNANDO, OCTAVIO PASCUAL, GERANAIA PASCUAL-DUBERT, and THE HONORABLE
PRESIDING JUDGE MANUEL S. PADOLINA of Br. 162, RTC, Pasig, Metro Manila, respondents.
G.R. No. 84240
March 25, 1992

PARAS, J.:
FACTS:
Petitioners Olivia and Hermes Pascual are the acknowledged natural children of the late Eligio Pascual,
the latter being a full blood brother of the decedent Don Andres Pascual, who died intestate without
any issue, legitimate, acknowledged natural, adopted or spurious children.. Adela Soldevilla Pascual
the surviving spouse of the late Don Andes Pascual filed w/ the RTC Branch 162, a special proceeding
case no.7554 for administration of the intestate estate of her late husband. Olivia and Hermes are
illegitimate children of Eligio Pascual (although they contend that the term illegitimate children as
described in art 992 should be construed as spurious children).

ISSUE:
Whether or not Article 992 of the Civil Code of the Philippines, can be interpreted to exclude
recognized natural children from the inheritance of the deceased.

HELD:
Article 992 of the Civil Code provides a barrier or iron curtain in that it prohibits absolutely a
succession ab intestato between the illegitimate child and the legitimate children and relatives of the
father or mother of said legitimate child. They may have a natural tie of blood, but this is not
recognized by law for the purposes of Article 992.
Eligio Pascual is a legitimate child but petitioners are his illegitimate children.
Applying the above doctrine to the case at bar, respondent IAC did not err in holding that petitioners
herein cannot represent their father Eligio Pascual in the succession of the latter to the intestate
estate of the decedent Andres Pascual, full blood brother of their father.