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### Facts:
1. **Death of Parents**: Basilio Balogbog and Genoveva Arnibal, parents of petitioners Leoncia and Gaudioso Balogbog, died intestate in 1951 and 1961 respectively.
2. **Claim by Respondents**: In 1968, respondents Ramonito and Generoso Balogbog claimed to be the legitimate children of Gavino Balogbog and Catalina Ubas, seeking their share in the estate of their grandparents.
3. **Denial by Petitioners**: Petitioners denied knowing the respondents, asserted that their brother Gavino had died single and childless, and later retracted an initial claim that the estate had been sold to them by their mother.
4. **Presentation of Witnesses**:
– **Priscilo Y. Trazo**: Former mayor testified about Gavino and Catalina being married in 1929.
– **Matias Pogoy**: Testified to attending Gavino and Catalina’s wedding and witnessing Gavino’s death in 1935 at his residence.
– **Catalina Ubas**: Testified to her marriage with Gavino and the birth of their three children.
5. **Absence of Official Records**: Certificates from various sources were presented indicating the non-availability of marriage and birth records purportedly destroyed during the war.
6. **Petitioners’ Evidence**:
– **Leoncia Balogbog**: Gavino died single.
– **Jose Narvasa**: Testified Gavino died single, and Catalina had children with another man post-war.
7. **Court Proceedings**:
– **Court of First Instance**: Ruled in favor of respondents declaring them legitimate grandchildren and entitled to their share.
– **Appeal to Court of Appeals**: Affirmed the decision of the lower court.
– **Supreme Court Petition**: Petitioners sought review of the decision.
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### Issues:
1. **Proof of Marriage**: Whether Gavino and Catalina’s marriage was adequately proven.
2. **Legitimacy of Children**: Whether the status of respondents as legitimate children was sufficiently established.
3. **Continuous Possession of Status**: Appropriateness of relying on continuous possession of status as legitimate children.
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### Court’s Decision:
1. **Proof of Marriage**:
– **Art. 53 and 54 Non-applicability**: The Court clarified that Articles 53 and 54 of the 1889 Civil Code never took effect in the Philippines.
– **Presumption of Marriage**: Current Civil Code and rules on evidence were applied. The court upheld the presumption of marriage based on continuous cohabitation and public repute despite the lack of formal registration.
– **Testimonies Considered Sufficient**: Eyewitness testimonies regarding the wedding were considered competent evidence to prove the marriage.
2. **Legitimacy of Children**:
– **Articles 266 and 267**: The legitimacy of the children can be proven by continuous possession of status as legitimate children if official documents are unavailable.
– **Testimonies Supporting Legitimacy**: Witnesses corroborated the contention that Ramonito and Generoso were children of Catalina and Gavino.
– **Admission by Gaudioso**: Gaudioso Balogbog’s admission during a police investigation that Ramonito was his nephew was substantial evidence against him.
3. **Continuous Possession of Status**:
– **Law’s Preference for Valid Marriages**: The court upheld the principle favoring the validity and sanctity of marriage and legitimate familial relationships.
– **Private Certification Inconclusive**: Lack of official records due to wartime destruction wasn’t sufficient to rebut the testimonies and continuous possession of status.
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### Doctrine:
1. **Presumption of Marriage**: When a man and woman have comported themselves as husband and wife, marriage is presumed valid unless cogent evidence disproves it.
2. **Continuity of Status**: In the absence of official records, continuous possession of status as legitimate children can be substantiated through credible testimonies and societal acknowledgment.
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### Class Notes:
– **Presumption of Validity in Marriage**: Marital relationships are presumed valid under civil law.
– **Proof of Legitimacy**:
– **Primary**: Certified civil registry records.
– **Secondary**: Continuous possession of status and supporting testimonies.
– **Civil Code (Old and New)**: Articles 266 and 267 of the new Civil Code allow flexibility in proving legitimacy in the absence of primary records.
– **Legal Statutes**:
– **Civil Code of the Philippines**:
– **Art. 265**: Birth records as proof of legitimate status;
– **Art. 266-267**: Alternative proof mechanisms in absence of birth records.
– **Rule 131, Sec. 5 (bb)**: Presumptions regarding the legal validity of conduct.
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### Historical Background:
– **Spanish Civil Code’s Partial Suspension**: Some provisions of the Spanish Civil Code of 1889 were suspended in the Philippines, rendering provisions like Arts. 53 and 54 inapplicable.
– **Post-War Record Destruction**: Historical context of wartime destruction impacting civil and ecclesiastical record availability was considered in judicial reasoning.
The Balogbog v. Court of Appeals case underscores the importance of presumption in legal marriages and continuous possession of legitimate child status in the absence of formal documentation.
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