**Facts:** The case originates from a Complaint for Compulsory Recognition and Enforcement of Successional Rights filed before the Regional Trial Court of Manila by minors Antonia Aruego and Evelyn Aruego, represented by their mother Luz M. Fabian. The complaint alleged that the minors were the illegitimate children of Jose M. Aruego, Sr., resulting from his relationship with Luz M. Fabian. The complaint sought recognition and a share in the deceased’s estate. The RTC ruled partially in favor of Antonia Aruego but dismissed claims regarding Evelyn Aruego. The petitioners contested this decision, citing the enactment of the Family Code of the Philippines and arguing that the action had prescribed. Their motion for reconsideration was denied, and subsequent appeals were dismissed by both the trial court and the Court of Appeals, maintaining the decision.
**Issues:** The main legal issues revolve around:
1. The applicability of the Family Code provisions to the action for recognition initiated under the Civil Code.
2. Whether the action had prescribed due to the enactment of the Family Code.
3. The vested rights of the private respondent under the old Civil Code versus the new provisions of the Family Code.
**Court’s Decision:** The Supreme Court held that the Family Code’s provisions could not retroactively be applied to the case as it would prejudice the vested rights of the private respondent. Since the complaint was filed under the regime of the Civil Code, it should be governed accordingly. The Supreme Court emphasized that jurisdiction once acquired is not lost despite the passage of new laws unless its application impairs vested rights. Therefore, the petition was denied, and the decision of the Court of Appeals was affirmed.
**Doctrine:** The decision reinforced the principle that the jurisdiction of a court, once attached, cannot be ousted by subsequent events or enactments that would have prevented jurisdiction from attaching in the first instance. It highlights the non-retroactivity of laws if they would impair vested rights.
**Class Notes:**
1. **Vested Rights:** Rights that have become an integral part of the legal assets of a person and are protected from legislative interference.
2. **Jurisdiction:** Once a court has legally acquired jurisdiction, it remains until its final decision on the matter.
3. **Retroactivity of Laws:** New laws have no retroactive effect if prejudicial to any vested rights, according to Article 256 of the Family Code.
4. **Prescriptive Period for Filiation Actions:** Under the Civil Code, illegitimate children could file for recognition within certain exceptions, even if the action is commenced after the death of the putative parent.
**Historical Background:** This case provides insight into the transitional legal conflicts encountered during the phased transition from the Philippines’ Civil Code to the Family Code. It illustrates the intricate balance courts must maintain between applying new legal standards and protecting established rights, a common challenge during periods of significant legal reform.
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