**Antonio Macadangdang vs. The Honorable Court of Appeals and Elizabeth Mejias**
### Facts:
* **March 1967**: Respondent Elizabeth Mejias, married to Crispin Anahaw, had intercourse with petitioner Antonio Macadangdang.
* **October 30, 1967**: Elizabeth Mejias gave birth to Rolando Macadangdang.
* **December 24, 1967**: Rolando Macadangdang was baptized.
* **April 25, 1972**: Elizabeth Mejias filed a complaint for recognition and support against Antonio Macadangdang in the Court of First Instance (CFI) of Davao.
* **June 30, 1972**: Macadangdang opposed the claim and sought its dismissal.
* **August 9, 1972**: Pre-trial conference led to certain stipulations and admissions; an amended complaint was filed on October 17, 1972.
* **February 27, 1973**: The CFI dismissed the complaint, invoking provisions of the Civil Code and Rules of Court.
* **April 18, 1973**: Mejias appealed the decision to the Court of Appeals.
* **June 2, 1978**: The Court of Appeals reversed the CFI decision, declaring Rolando an illegitimate son of Macadangdang.
* **November 6, 1978**: Court of Appeals denied motions for reconsideration.
* **January 12, 1979**: Macadangdang filed a petition for review in the Supreme Court.
### Issues:
1. Whether Rolando is conclusively presumed the legitimate issue of Elizabeth Mejias and Crispin Anahaw.
2. Whether a wife may institute an action that would bastardize her child without giving her husband, the legally presumed father, an opportunity to be heard.
### Court’s Decision:
**Issue 1: Presumption of Legitimacy**
* The Court emphasized that under Article 255 of the Civil Code, children born after 180 days following marriage and before 300 days following its dissolution or separation of the spouses are presumed legitimate unless proved otherwise.
* The evidence needed to rebut this presumption is the physical impossibility of the husband having access to his wife within the first 120 days preceding the birth of the child.
* The Court found no substantial evidence proving that Crispin Anahaw physically lacked access to Mejias during the period of conception.
* The Court noted a discrepancy between Elizabeth Mejias’ claims of separation in 1967 and the actual evidence presented, which did not corroborate her statements.
* The child being born seven months after the purported first illicit contact with Macadangdang suggests that Rolando is not the son of Macadangdang but rather the legitimate son of Anahaw.
**Issue 2: Wife Instituting an Action to Bastardize Child**
* The Court held that only the husband could contest the legitimacy of a child born during the marriage.
* A mother cannot declare her child illegitimate to gain any benefit due to moral and public policy considerations.
* Since Mejias’ claim lacked corroborative evidence and her husband was not impleaded, there was no due process given to the legally presumed father.
### Doctrine:
1. **Presumption of Legitimacy**: Children born after 180 days following marriage and before 300 days following its dissolution or separation are presumed legitimate.
2. **Physical Impossibility of Access**: This must be proven to overcome the presumption of legitimacy, caused by impotence, separate living arrangements that prohibit access, or serious illness of the husband.
3. **Action to Contest Legitimacy**: Only the husband can contest the legitimacy of a child born in wedlock, and any action to declare a child illegitimate must provide the husband an opportunity to be heard.
### Class Notes:
1. **Presumption of Legitimacy** (Art. 255, Civil Code):
– Presumption applies if the child is born 180-300 days after marriage/its dissolution.
– Can only be rebutted by evidence showing physical impossibility of access within the first 120 days of the 300-day period before birth.
2. **Quasi-conclusive Presumptions**:
– Impossibility of access may arise due to impotence, husband and wife living separately, or serious illness of the husband (Rule 131, Rules of Court).
3. **Right to Contest Legitimacy**:
– Exclusively the husband’s right (Tolentino’s Commentaries citing Cases and Jurisprudence).
### Historical Background:
This case took place in the Philippines during a time when the family code placed a high importance on marital fidelity and the legitimacy of children born within a marriage. The decision emphasizes the courts’ inclination to stabilize familial structures despite claims of adultery, reflecting the sociocultural context of the late 20th century Philippines. The strict rules around proving illegitimacy highlight the importance given to protecting the interests of children against declarations of illegitimacy without strong evidence.
Leave a Reply