Facts: The petitioner, Eugenio San Juan Geronimo (Eugenio), is disputing the legitimacy of the respondent, Karen Santos, as the legal heir to properties left by deceased spouses Rufino and Caridad Geronimo. Karen claims to be the only child and therefore the rightful heir by intestacy upon her parents’ death. Eugenio and his brother Emiliano contested this claim, arguing that Karen was not their niece but rather the child of Caridad’s sister, and that the deceased couple was childless.
Karen discovered that the defendants executed a document entitled “Pagmamana sa Labas ng Hukuman” which indicated that they were the only heirs of the deceased, and as a result, they acquired possession and transferred tax declarations to their names. Karen’s birth certificate was questioned by Eugenio for having alterations in the date of birth and the informant’s signature.
The trial court, followed by the Court of Appeals (CA), ruled in Karen’s favor, establishing that she is the legitimate child and declaring the document “Pagmamana sa Labas ng Hukuman” as null and void. Emiliano was excused from the case after Eugenio stated he was unsure whether Emiliano was still alive and that he did not verify the petition.
Issues:
1. Whether secondary evidence of Karen’s legitimate filiation is admissible despite the existence of her birth certificate.
2. Whether Eugenio has the legal personality to question Karen’s legitimate filiation in an action for annulment of document and recovery of possession.
Court’s Decision:
In its detailed resolution, the Philippine Supreme Court agreed with the petitioner that secondary evidence to prove filiation is only admissible in a direct action under Article 172 and cannot be raised as a collateral issue in another action for different purposes. As such, Eugenio’s questioning of Karen’s filiation as a collateral matter is permitted, as he is not impugning her legitimacy, but rather her relationship to the deceased as a child at all.
Despite earlier court decisions, the Supreme Court examined the evidence and circumstances surrounding Karen’s birth and found inconsistencies and reasons to doubt her claim as the child of the deceased spouses. These included alterations in her birth certificate, lack of evidence concerning Caridad’s maternity leave or evidence of pregnancy, and the unlikelihood of a child bearing at an advanced maternal age without supportive documentation or testimonial evidence.
Doctrine:
The doctrine established is that the legitimacy of a child can be contested outside the strict confines of Articles 170 and 171 of the Family Code by those who are not the presumed parent or his heirs when the claim being raised is not the child’s legitimacy but whether they are a child of the couple at all.
Historical Background:
Historically, proving a child’s legitimacy was a straightforward matter often determined by marriage and birth records. However, with the rise of more complex family arrangements and reproductive technologies, the Philippine court system faced challenges in adjudicating claims of filiation, leading to evolving interpretations of the Family Code. The case at hand reflects such evolution, allowing more significant discretion to the courts in determining the rights of contested heirs when facts are under dispute.
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