### **Facts:**
This case concerns Arhbencel Ann Lopez (Arhbencel), represented by her mother Araceli Lopez, who filed a complaint against Ben-Hur Nepomuceno (petitioner) in the Regional Trial Court (RTC) of Caloocan City, seeking recognition as his illegitimate daughter and financial support. Arhbencel was born on June 8, 1999, purportedly from an extramarital affair between the petitioner and Araceli. Nepomuceno refused to sign Arhbencel’s birth certificate but later issued a handwritten note promising to provide financial support. The RTC initially granted Arhbencel support pendente lite, but after evaluating the evidence, dismissed the case due to insufficiency of evidence regarding filiation.
Arhbencel appealed to the Court of Appeals (CA), which reversed the RTC’s decision, recognizing her as Nepomuceno’s illegitimate daughter and ordered increased support. Nepomuceno’s subsequent motion for reconsideration was denied, leading him to file a Petition for Review on Certiorari to the Supreme Court.
### **Issues:**
1. Whether the handwritten note of the petitioner suffices as recognition of paternity.
2. If said note can establish the filiation of Arhbencel as an illegitimate child of Nepomuceno.
3. The legitimacy of the demand for financial support based on the alleged paternity.
### **Court’s Decision:**
The Supreme Court granted Nepomuceno’s petition, setting aside the decision of the CA and reinstating the RTC’s order dismissing the case for insufficiency of evidence. The Court held that the handwritten note did not explicitly acknowledge Arhbencel’s filiation to Nepomuceno nor did it qualify as an authentic writing that could establish illegitimate filiation under Articles 172 and 175 of the Family Code. As such, the demand for support, predicated on the unproven claim of filiation, was not substantiated.
### **Doctrine:**
The Court reiterated the principle that for a claim of filiation in the context of illegitimate children to be successful, it must either be recognized by the putative parent in the record of birth, a will, a statement before a court of record, or in any authentic writing. Absent such recognition, claims for financial support from the alleged parent cannot be sustained.
### **Class Notes:**
– Filiation can be established by the record of birth, an admission in a public document, or a private handwritten instrument signed by the parent concerned.
– Authentic writing is pivotal for voluntary recognition by a parent.
– A handwritten note promising financial support without acknowledging paternity cannot solely substantiate a claim of illegitimate filiation.
– The entitlement to support is contingent upon the successful establishment of filiation.
Relevant Legal Statutes and Provisions:
– Articles 172, 175, 194, 195, and 196 of the Family Code of the Philippines, which govern the establishment of filiation and the consequent entitlement to support.
– Herrara v. Alba, which discusses the evidence required to establish illegitimate filiation comprehensively.
### **Historical Background:**
This case reflects the complexity of establishing filiation and support for illegitimate children in the Philippines, underscoring the balance between the rights and obligations arising from parental recognition and the substantiation of filiation claims within the legal framework provided by the Family Code. The decision mirrors the judiciary’s cautious approach in filiation cases, particularly in avoiding unfounded claims disrupting the putative parent’s life and the importance of authentic writing in voluntary acknowledgment by a parent.
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