Being born outside marriage does not prevent a child from inheriting from a biological parent in the Philippines. An illegitimate child—also called a nonmarital child in recent Supreme Court decisions—is a compulsory heir once filiation, or the legal parent-child relationship, is properly established. The difficult part is often not the right itself, but proving filiation, being included in the estate settlement, calculating the correct share, and stopping other heirs from transferring the property without you.

This guide explains the inheritance rights of an illegitimate child, the evidence needed to prove filiation, the difference between estates with and without a will, and the practical steps for claiming a share through an extrajudicial or judicial settlement.

Does an Illegitimate Child Have Inheritance Rights in the Philippines?

Yes. Article 887 of the Civil Code includes illegitimate children among the deceased person’s compulsory heirs. A compulsory heir is someone whom the law protects by reserving a minimum portion of the estate, called the legitime.

Article 176 of the Family Code provides that the legitime of each illegitimate child is generally one-half of the legitime of a legitimate child. The law still uses the term “illegitimate,” although the Supreme Court increasingly uses “nonmarital child” because a child should not be blamed or stigmatized based on the parents’ marital status. (Lawphil)

The right to inherit arises at the moment the parent dies. Article 777 of the Civil Code states that succession rights are transmitted from the moment of death, although the estate must still be settled, its debts paid, and the heirs’ specific shares determined. (Lawphil)

An illegitimate child does not need to have lived with the parent, carried the parent’s surname, or received financial support to inherit. The central legal requirement is that filiation must be duly proved.

The Most Important Requirement: Proving Filiation

Filiation means the legally recognized relationship between a parent and child. In inheritance disputes, claiming that the deceased treated you like a son or daughter may not be enough unless the claim is supported by evidence recognized under Articles 172 and 175 of the Family Code.

Strong forms of proof

Filiation may be established through any of the following:

A record of birth appearing in the civil register in which the parent legally participated or acknowledged the child;
A final court judgment establishing filiation;
An admission of filiation in a public document, such as a notarized affidavit or deed;
A private handwritten instrument signed by the parent, such as a signed letter clearly admitting parenthood;
Open and continuous possession of the status of a child; or
Other evidence allowed by the Rules of Court and special laws, which may include DNA evidence, family records, photographs, school records, financial support records, correspondence, and credible testimony. (Lawphil)

Is a birth certificate enough?

A Philippine Statistics Authority birth certificate is usually the first document examined, but its value depends on how it was prepared.

If the alleged father signed or executed the acknowledgment appearing on the birth record, the certificate can be strong evidence of filiation. If the father’s name was merely entered by the mother, doctor, or registrar without the father’s participation or signature, the certificate may not be competent proof of paternal filiation by itself.

The Supreme Court has repeatedly held that a birth certificate naming an alleged father, but not signed or acknowledged by him, does not automatically prove paternity. ([Lawphil][3])

Using the father’s surname under Republic Act No. 9255 may support the claim, but the surname alone does not create inheritance rights. The underlying acknowledgment of paternity remains important. Republic Act No. 9255 amended Article 176 of the Family Code to allow an illegitimate child to use the father’s surname when filiation has been expressly recognized. ([Lawphil][4])

Time limits for establishing filiation

The applicable deadline depends on the type of evidence available.

Basis of the claim	General period for bringing the action
Civil-registry birth record properly involving the parent	During the child’s lifetime
Final judgment of filiation	Already judicially established
Public document admitting filiation	During the child’s lifetime
Private handwritten instrument signed by the parent	During the child’s lifetime
Open and continuous treatment as a child	Generally during the alleged parent’s lifetime
Other evidence, including testimony or circumstantial proof	Generally during the alleged parent’s lifetime, subject to exceptional jurisprudence

The distinction is critical. Article 175 generally allows a claim based on the stronger documentary evidence in the first paragraph of Article 172 to be brought during the child’s lifetime. A claim based only on open and continuous possession of child status or other secondary evidence ordinarily must be filed while the alleged parent is alive. ([Lawphil][5])

Do not assume that DNA testing automatically cures a late claim. The Supreme Court recognizes DNA as a valid method of determining filiation, but the timing of the action, available documentary evidence, and unusual facts of the case can affect whether testing will be ordered.

In Aquino v. Aquino, G.R. Nos. 208912 and 209018, December 7, 2021, the Supreme Court remanded the case for further evidence, including DNA evidence, where the alleged father had died before the claimant was born. The case involved exceptional facts and a claim to inherit from a grandparent by representation. ([Supreme Court of the Philippines][6])

How Much Can an Illegitimate Child Inherit?

The answer depends on:

Whether the deceased left a valid will;
Whether there is a surviving spouse;
Whether there are legitimate children;
Whether there are other illegitimate children;
Whether the deceased’s parents are still alive;
Which properties actually belonged to the deceased; and
The estate’s debts, taxes, and expenses.

First separate the surviving spouse’s property

Before dividing the inheritance, determine which assets belonged exclusively to the deceased and which formed part of the spouses’ absolute community or conjugal partnership.

In many marriages, the surviving spouse already owns a share of the community or conjugal property. That ownership share is not an inheritance. Only the deceased spouse’s share enters the estate.

Under Articles 102 and 129 of the Family Code, the net community or conjugal assets are ordinarily divided equally between the spouses unless a valid marriage settlement or another legal rule provides otherwise. (Lawphil)

For example, assume a house worth ₱6 million is community property and there are no community debts. The surviving spouse ordinarily owns ₱3 million after liquidation. Only the deceased’s ₱3 million share becomes part of the hereditary estate to be divided among the heirs.

If there is no will

When a person dies without a valid will, the estate is distributed through intestate succession.

Surviving heirs	General intestate distribution
Only illegitimate children	They divide the entire net estate equally
Surviving spouse and illegitimate children only	Spouse receives one-half; illegitimate children collectively receive one-half
Legitimate and illegitimate children	Each illegitimate child generally receives one-half of the share of each legitimate child
Legitimate children, illegitimate children, and spouse	Spouse generally receives a share equal to one legitimate child; each illegitimate child receives half of a legitimate child’s share
Legitimate parents or ascendants and illegitimate children	Ascendants collectively receive one-half; illegitimate children collectively receive one-half
Legitimate ascendants, spouse, and illegitimate children	Ascendants receive one-half, spouse one-fourth, and illegitimate children collectively one-fourth

These rules come principally from Articles 983, 988, 991, and 998 to 1000 of the Civil Code, as affected by Article 176 of the Family Code. (Lawphil)

Example: legitimate and illegitimate children

Suppose the net estate is ₱5 million and the deceased left:

Two legitimate children;
One illegitimate child; and
No surviving spouse.

Use proportional units:

Each legitimate child: 1 unit;
Illegitimate child: 0.5 unit.

The total is 2.5 units. Each legitimate child receives ₱2 million, while the illegitimate child receives ₱1 million.

Example: spouse, legitimate children, and illegitimate child

Suppose the net estate is ₱7 million and the deceased left:

Two legitimate children;
One illegitimate child; and
A surviving spouse.

The spouse and each legitimate child receive one full unit. The illegitimate child receives half a unit. The total is 3.5 units:

Surviving spouse: ₱2 million;
Legitimate child 1: ₱2 million;
Legitimate child 2: ₱2 million;
Illegitimate child: ₱1 million.

Actual computations may change when representation, adoption, disinheritance, prior donations, several marriages, or disputed property ownership is involved.

If the parent left a will

A parent cannot freely give away the entire estate when compulsory heirs exist.

Article 886 defines the legitime as the portion of the estate that the testator cannot dispose of because the law reserves it for compulsory heirs. Articles 904, 906, and 907 allow an heir whose legitime was denied or reduced to demand completion of the share and reduction of excessive testamentary gifts. (Lawphil)

Some common rules are:

If illegitimate children are the only compulsory heirs, they are collectively entitled to one-half of the estate as their legitime. The other half is generally the free portion.
If a surviving spouse and illegitimate children are the only compulsory heirs, the spouse is generally entitled to one-third, the illegitimate children collectively to one-third, and the remaining third is disposable.
If legitimate children also survive, each illegitimate child’s legitime is generally one-half of the legitime of each legitimate child, subject to rules protecting the spouse and limiting the total charge against the disposable portion.

A will does not operate automatically. Under the Rules of Court, a will must be submitted for probate, which is the court process for proving that the will was validly executed. Family members cannot simply follow a private copy of a will and bypass probate. Rules on settlement of estates and probate are found principally in Rules 73 to 90. ([Lawphil][7])

What if the illegitimate child was completely omitted from the will?

Complete omission may constitute preterition under Article 854 if the omitted person is a compulsory heir in the direct line and received nothing by will, legacy, devise, or prior advance chargeable to the inheritance.

Preterition can annul the institution of heirs, although valid legacies and devises may remain effective to the extent that they do not impair compulsory shares. Whether an omission is preterition depends on the wording of the will and whether the omission was total. (Lawphil)

Can a parent legally disinherit an illegitimate child?

Only through a valid will and only for a cause expressly recognized by law.

Articles 915 to 919 require the will to state the legal cause for disinheritance. The other heirs carry the burden of proving that cause if the disinherited child denies it. Family conflict, disapproval of the child’s mother, lack of closeness, or the child’s refusal to use the father’s surname are not automatically valid grounds. (Lawphil)

Step-by-Step Guide to Claiming Your Inheritance

1. Obtain the parent’s death certificate

Request a PSA-certified death certificate or obtain a certified copy from the local civil registrar if the PSA copy is not yet available.

Confirm:

Full name of the deceased;
Date and place of death;
Last residence;
Civil status; and
Name of the surviving spouse, when shown.

The last residence affects the proper court and BIR Revenue District Office.

2. Gather your evidence of filiation

Start with the strongest available records:

PSA birth certificate;
Affidavit of acknowledgment or admission of paternity;
Affidavit to Use the Surname of the Father;
Baptismal and school records;
Signed letters, cards, emails, or messages from the parent;
Insurance, employment, hospital, SSS, GSIS, or PhilHealth records listing you as a child or beneficiary;
Proof of regular financial support;
Family photographs and correspondence;
Statements of relatives or persons with personal knowledge; and
Prior court orders involving support, custody, or paternity.

Preserve originals. Do not write on, alter, or staple irreplaceable handwritten documents. Obtain certified copies where possible.

3. Determine whether there is a will or an existing estate case

Ask the family whether a will exists and check whether probate or estate-administration proceedings have already been filed in the Regional Trial Court.

If an estate case is pending, obtain the case number, branch, petition, inventory, published notices, and relevant court orders. File an appropriate appearance, opposition, motion, or claim rather than starting a second proceeding involving the same estate.

4. Identify all heirs and estate properties

Prepare a family tree showing:

Surviving spouse;
Legitimate children;
Illegitimate children;
Adopted children;
Predeceased children and their descendants;
Surviving parents or grandparents; and
Children from previous relationships or marriages.

Prepare a separate estate inventory covering:

Land, houses, and condominium units;
Vehicles;
Bank deposits;
Shares of stock and business interests;
Insurance proceeds payable to the estate;
Receivables;
Personal property of substantial value;
Debts and mortgages; and
Properties transferred or donated shortly before death.

Remember that property registered in the deceased’s name may still be community, conjugal, co-owned, held in trust, or subject to another person’s ownership claim.

5. Formally notify the other heirs

Send a written notice stating that:

You are claiming as a child and compulsory heir;
You must be included in the inventory and settlement;
No deed should be signed excluding you;
No estate property should be sold without proper settlement; and
You are requesting copies of any will, extrajudicial settlement, tax filing, title, and court pleading.

A documented notice can help establish that the other heirs knew of your claim before signing documents or selling property.

6. Determine whether an extrajudicial settlement is possible

An extrajudicial settlement of estate, commonly called an EJS, may generally be used when:

The deceased left no will;
The estate has no unpaid debts, or the debts have been settled;
All heirs are identified;
All heirs agree on the settlement;
All heirs are adults, or minors are properly represented by authorized legal or judicial representatives; and
Every heir participates in the notarized public instrument.

Rule 74 requires publication of the fact of settlement in a newspaper of general circulation. The usual publication is once a week for three consecutive weeks. The document is then used for BIR processing and, for land, registration with the Registry of Deeds. ([Lawphil][8])

An EJS excluding a known illegitimate child is not automatically binding on that omitted heir. Rule 74 expressly protects persons who did not participate or had no notice, and the Supreme Court has invalidated estate partitions that excluded lawful heirs. ([Supreme Court E-Library][9])

7. Use judicial settlement when there is disagreement

Judicial proceedings are usually necessary when:

A will exists;
Filiation is disputed;
An heir refuses to sign;
An heir was concealed or omitted;
Estate debts remain unresolved;
A minor or incapacitated heir is not properly represented;
Property ownership is disputed;
Original titles or important records are missing;
The estate needs an administrator; or
Property must be preserved, sold, or managed under court authority.

The proceeding is generally filed in the Regional Trial Court of the province or city where the deceased resided at the time of death. If the deceased was not a Philippine resident, venue is generally where the estate or a portion of it is located.

Depending on the facts, the claimant may seek:

Probate or allowance of a will;
Issuance of letters of administration;
Recognition or determination of heirship;
Inclusion in the inventory and project of partition;
Judicial partition;
Annulment of an extrajudicial settlement;
Reconveyance of property;
Accounting of income, rent, or sale proceeds;
Injunction against an improper transfer; or
Annotation of a pending case on the property title through a notice of lis pendens, when legally proper.

Barangay officials cannot probate a will, appoint an estate administrator, determine conclusively who the legal heirs are, or order the Registry of Deeds to transfer title. Barangay mediation may help with certain local disputes, but it does not replace the required court or estate-settlement process.

8. Process estate tax and property transfers

For deaths covered by the TRAIN Law, the estate tax is generally 6% of the net taxable estate. BIR Form No. 1801 is ordinarily filed within one year from death. In meritorious cases, the BIR may grant a filing extension not exceeding 30 days, while qualified estates may request an extension or installment arrangement for payment.

The estate normally needs:

An estate Taxpayer Identification Number, commonly registered through BIR Form No. 1904;
BIR Form No. 1801;
Death certificate;
Birth and marriage records establishing the heirs;
Will and probate documents, if applicable;
Notarized extrajudicial settlement or court order;
Inventory and valuation of assets;
Titles and tax declarations;
Proof of allowable deductions and liabilities; and
A certified public accountant’s statement when required for estates above the applicable gross-value threshold.

After payment and verification, the BIR issues an electronic Certificate Authorizing Registration or eCAR. Registered land, shares, and similar property generally cannot be transferred to the heirs without the appropriate eCAR.

For land, the usual next steps include:

Payment of applicable local transfer tax;
Securing real-property-tax clearances;
Filing the deed, court order, eCAR, title, and supporting papers with the Registry of Deeds;
Issuance of a new title in the heirs’ names; and
Updating the tax declaration with the city or municipal assessor.

Documents Commonly Required

Document	Why it matters
PSA death certificate	Proves death and opens succession
Claimant’s PSA birth certificate	Primary starting evidence of filiation
Signed acknowledgment or admission	Strengthens proof of paternal filiation
PSA marriage certificate of the deceased	Establishes surviving spouse and family status
Birth and death certificates of other heirs	Establishes the complete family tree
Will and probate papers	Determines testamentary rights
Land titles and tax declarations	Identifies and values real property
Bank, stock, and business records	Identifies personal and financial assets
Extrajudicial settlement or court orders	Establishes the legal mode of settlement
BIR forms, payment records, and eCAR	Required for tax clearance and transfer
Valid IDs, TINs, and specimen signatures	Required by notaries, banks, BIR, and registries
Apostilled foreign documents	Needed when records or signatures originate abroad
Special power of attorney	Allows an authorized representative to act for an heir abroad

Practical Timelines and Costs

There is no single national processing time because estates differ greatly.

Stage	Practical timing
Obtaining PSA and local civil-registry records	Several days to several weeks
EJS negotiation and document preparation	Weeks to several months
Mandatory newspaper publication	Three consecutive weekly publications
BIR review and eCAR processing	Commonly weeks to several months, depending on completeness and RDO workload
Registry of Deeds transfer	Commonly several weeks to several months
Uncontested estate from documents to title transfer	Often several months
Contested filiation, probate, or partition case	Frequently several years

Possible expenses include:

PSA and civil-registry fees;
Notarial fees;
Newspaper publication;
Estate tax and penalties, if applicable;
Local transfer tax;
Registry of Deeds fees;
Certified copies and title verification;
Court filing and publication fees;
Commissioner, appraiser, accountant, or administrator expenses;
DNA testing and expert testimony; and
Authentication, apostille, translation, and courier charges for overseas documents.

Notarial fees and legal-document costs often depend on the number and value of the properties. Publication charges vary by newspaper and location.

Common Problems Illegitimate Children Face

The family says, “Your name is not on the title”

An heir’s name does not need to appear on the parent’s title before death. Succession rights arise by law when the parent dies. The title is later transferred through estate settlement.

The legitimate family denies knowing about the child

Lack of family knowledge does not erase filiation. The claim will depend on legally admissible evidence, not on whether the surviving spouse or other children approve.

The father’s name appears on the birth certificate, but he did not sign it

This is a serious evidence issue. Gather other signed admissions, public documents, support records, correspondence, and evidence of how the father treated the child. The deadline rules under Article 175 must be examined immediately.

The other heirs already signed an extrajudicial settlement

Obtain a certified copy from the notary, newspaper, BIR records available through proper process, or Registry of Deeds. Check whether you were named, whether the document falsely stated that there were no other heirs, and whether the properties have already been transferred or sold.

Rule 74’s two-year protection period is important, but it is not always an absolute bar against an heir who was excluded, had no notice, or was affected by fraud. The applicable remedy and limitation period depend on participation, notice, registration, fraud, and whether a third-party buyer is involved. Act promptly rather than assuming that an omitted heir has unlimited time. ([Supreme Court E-Library][10])

A property was sold before the estate was settled

A co-heir generally cannot sell a specific physical portion of estate property as though that portion exclusively belonged to that heir. Before partition, an heir ordinarily holds an undivided hereditary interest. A transfer may affect only whatever share is ultimately allotted to the seller, subject to the rights of other heirs and good-faith purchasers.

A sibling asks you to waive your inheritance

Do not treat a waiver as a routine signature. A renunciation may be permanent, and a waiver favoring a specific heir or specific property may create donor’s-tax consequences.

BIR Revenue Memorandum Circular No. 94-2021 distinguishes a general renunciation from arrangements in which an heir gives up value in identified properties so another heir receives more than the proper share. The value forgone in a specific or partial renunciation may be subject to donor’s tax. ([Bir Cdn][11])

The parent transferred everything before death

Lifetime transfers are not automatically untouchable. Donations to children may be charged against their legitimes, and excessive donations may be reduced if they impair compulsory heirs. Sham sales, simulated transfers, or transactions made without genuine consideration may also be challenged when supported by evidence.

Rights When Inheriting From Grandparents or Other Relatives

Article 992 of the Civil Code contains the historically controversial “iron curtain rule,” which restricts certain intestate inheritance between illegitimate children and the legitimate relatives of their parents.

The Supreme Court significantly narrowed that doctrine in Aquino v. Aquino. It ruled that grandparents and other direct ascendants are not included among the “relatives” barred by Article 992. A nonmarital grandchild may therefore inherit from a grandparent by right of representation when the child’s parent—who would have inherited—died before the grandparent. ([Supreme Court of the Philippines][6])

Example: Ana is the nonmarital child of Ben. Ben dies before his father, Carlos. When Carlos later dies, Ana may represent Ben and claim the share Ben would have received, provided Ana proves her filiation to Ben and the other legal requirements are met.

The ruling does not erase every restriction involving collateral relatives, such as a parent’s legitimate siblings. Claims involving grandparents, siblings, uncles, aunts, nephews, or nieces require careful identification of the direct and collateral family lines.

Special Considerations for Heirs Abroad and Foreigners

Filipino heir living abroad

An overseas heir does not lose inheritance rights by living outside the Philippines.

The heir may usually authorize a Philippine representative through a special power of attorney specifically covering estate settlement, BIR filings, court participation, signing of deeds when legally allowed, and Registry of Deeds transactions.

A document signed abroad generally needs:

Notarization under the law of the country where it is signed;
An apostille if issued in a country that is a party to the Apostille Convention; or
Authentication or legalization when the issuing country is not covered by the apostille system.

Documents not written in English or Filipino may also require a certified translation. DFA guidance confirms that apostilled documents from contracting countries generally no longer require separate Philippine Embassy authentication. ([Philippine Embassy in New Delhi][12])

Foreign child of a Filipino parent

A foreign national may inherit from a Filipino parent. For a Filipino decedent, Philippine law generally governs the order of succession, the amount of hereditary rights, and the intrinsic validity of testamentary provisions under Article 16 of the Civil Code. ([Lawphil][13])

Foreign birth certificates, marriage certificates, judgments, and acknowledgment documents should be apostilled or properly legalized and translated when necessary.

Can a foreigner inherit Philippine land?

Article XII, Section 7 of the 1987 Constitution generally prohibits transfers of private land to foreigners but expressly recognizes an exception for hereditary succession. A foreign heir may therefore acquire Philippine private land through inheritance, subject to proper estate settlement, tax clearance, and title registration. ([Lawphil][14])

The inheritance exception does not permit the family to disguise an ordinary sale or donation as succession. A foreign heir who later transfers the land must also comply with constitutional and registration requirements.

If the deceased parent was a foreign national

Article 16 of the Civil Code generally makes the deceased person’s national law relevant to the order of succession, the amount of inheritance rights, and the intrinsic validity of the will.

Philippine courts may require competent proof of the foreign law. If it is not properly pleaded and proved, procedural complications can arise. Philippine procedures still govern the settlement, probate, taxation, and registration of assets located in the Philippines.

A will already probated abroad may require reprobate or allowance in the Philippines under Rule 77 before it can affect Philippine property.

Frequently Asked Questions

Can an illegitimate child inherit even if the father never supported the child?

Yes. Lack of support does not remove inheritance rights. The child must still prove filiation through evidence recognized by law.

Does an illegitimate child need to use the father’s surname to inherit?

No. A child may inherit without using the father’s surname. Surname use and inheritance are separate issues, although documents connected with acknowledgment may help prove filiation.

Can an illegitimate child inherit if the birth certificate has no father listed?

Possibly. Other evidence may establish filiation, but the time limits under Article 175 become especially important. Claims relying only on secondary evidence may need to have been filed during the alleged parent’s lifetime.

Can legitimate children exclude an illegitimate child from an extrajudicial settlement?

No. All legal heirs must be included. An extrajudicial settlement is not binding on an heir who did not participate and had no notice, although delay can make recovery more difficult.

Is an illegitimate child entitled to half of the entire estate?

Not automatically. “One-half” usually refers to the relationship between the legitime of an illegitimate child and that of a legitimate child. The actual percentage depends on all surviving heirs and whether there is a will.

Can an illegitimate child inherit the same amount as a legitimate child?

The general rule is that each illegitimate child receives one-half of the share or legitime of each legitimate child. However, when no legitimate children exist, an illegitimate child may receive a much larger proportion, including the entire estate when illegitimate children are the only intestate heirs.

Can DNA testing be requested after the father has died?

It may be possible through preserved samples or testing of close biological relatives, but the court will consider relevance, procedural fairness, available documentary proof, and the time limits for establishing filiation. DNA is not an automatic substitute for filing a timely claim.

What happens if the deceased left only an illegitimate child and no spouse?

If there is no will and no legitimate descendants or ascendants who would concur under the Civil Code, the illegitimate child may inherit the entire net estate. If there is a will and the child is the only compulsory heir, the protected legitime is generally one-half, while the other half is ordinarily disposable.

Can an illegitimate child inherit from a grandparent?

Yes, in appropriate cases. Under Aquino v. Aquino, a nonmarital child may inherit from a grandparent or other direct ascendant by representing a deceased parent, provided filiation and the right of representation are established.

Can an inheritance claim be made after the property has been transferred?

Possibly. Available remedies may include annulment of settlement, partition, reconveyance, accounting, or recovery of the heir’s share. The result depends on notice, fraud, registration, limitation periods, and whether the property reached an innocent purchaser for value.

Key Takeaways

An illegitimate child is a compulsory heir of a biological parent once filiation is duly proved.
The child’s legitime is generally one-half of the legitime of a legitimate child, but the actual percentage depends on the complete family situation.
A father’s unsigned name on a birth certificate may not be enough to prove paternal filiation.
Claims based only on secondary evidence may be subject to the rule requiring action during the alleged parent’s lifetime.
A will cannot validly deprive an illegitimate child of the legitime without lawful disinheritance.
Every legal heir must be included in an extrajudicial settlement.
The surviving spouse’s own community or conjugal share must be separated before the inheritance is calculated.
Estate tax, BIR eCAR, local taxes, and Registry of Deeds requirements must be completed before registered assets are transferred.
Overseas and foreign heirs may claim inheritance using properly apostilled, legalized, or consularized documents.
Under Aquino v. Aquino, a nonmarital child may inherit from grandparents and other direct ascendants by right of representation.