Short answer. Only downward. Article 972 states that the right of representation takes place in the direct descending line, but never in the ascending. Grandchildren can represent a deceased parent to inherit from a grandparent, but a grandparent can never represent a deceased child to inherit through that child's own descendants.
What the law says
The right of representation takes place in the direct descending line, but never in the ascending.
Civil Code, Article 972 — Where Representation Operates. Read the full provision →
What the law says
In the collateral line, it takes place only in favor of the children of brothers or sisters, whether they be of the full or half blood.
Civil Code, Article 972 — Where Representation Operates. Read the full provision →
Representation runs downward only
Article 972 is direct about the limit: The right of representation takes place in the direct descending line, but never in the ascending. Representation lets a descendant step into the place of a parent who died before the person whose estate is being settled, so grandchildren can inherit the share their deceased parent would have received from a grandparent. The reverse simply does not exist in the law. A grandparent cannot represent a child who predeceased them in order to reach that child's own children's estate; the ascending line has no equivalent right.
The collateral line has its own narrow exception
The article adds one more limit on where representation applies outside the direct descending line: In the collateral line, it takes place only in favor of the children of brothers or sisters, whether they be of the full or half blood. So a nephew or niece can represent a deceased parent to inherit alongside their surviving aunts or uncles, but representation in the collateral line stops there. It does not extend further out to cousins representing their own deceased parents in place of a great-aunt or great-uncle, for instance.
Why the law draws the line this way
Representation exists to prevent a line of descendants from losing their share simply because the person who would have inherited died first. That reasoning naturally points downward, toward the deceased heir's own children, who are continuing that same line. It does not translate upward, because an ascendant is not continuing a line through the deceased descendant in the same sense; the law instead relies on the ordinary order of intestate succession among ascendants and other relatives to handle those situations.
What this means for grandparents and grandchildren
If your parent died before your grandparent, and your grandparent has since died, you can generally represent your deceased parent and inherit the share your parent would have received. But if your own child died before you, you cannot use representation to reach into an estate through that child; your rights would instead depend on the ordinary rules of succession that apply to you directly, not on standing in your deceased child's place.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Martin Roberto G. Tirol vs. Sol Nolasco, G.R. No. 230103, August 27, 2020 — read the decision on LawPhil →
- Ma. Elena R. Divinagracia as Administratrix of the Estate of the Late Santiago C. Divinagracia vs Coronacion Parilla, et al, G.R. No. 196750, March 11, 2015 — read the decision on LawPhil →
- Estate of Tarcila vda. de Villegas vs. Jesus R. Gaboya, et al, G.R. No. 143006, July 14, 2006 — read the decision on LawPhil →
- In the matter of the intestate etc. vs. Heirs of Marciana Rustia Vda. De Damian, et al, G.R. No. 155733, January 27, 2006 — read the decision on LawPhil →