**Facts:**
1. **Birth and Early Life of Josefa Mendoza (1893):** Josefa Mendoza was allegedly born in 1893 as the natural daughter of Claro Bustamante and Paula Mendoza, out of wedlock. Claro Bustamante reportedly raised and introduced Josefa as his daughter.
2. **Document of Recognition (1929):** Shortly before his death in March 1929, Claro Bustamante gave Josefa a private document (Exhibit G) acknowledging her as his natural daughter.
3. **Loss of Document (1941):** Josefa lost possession of the document during World War II in 1941 amidst the chaos.
4. **Extrajudicial Partition (Post-1929):** After Claro Bustamante’s death, his widow Teodora Cayas and his legitimate son, Nicasio Bustamante, extrajudicially partitioned his estate.
5. **Rediscovery of Document (1953):** The document was rediscovered by Josefa in 1953.
6. **Filing of Petition (1953):** On May 6, 1953, Josefa filed a petition against Teodora Cayas and Monica Nazareno (heir of Nicasio Bustamante) seeking judicial administration of the estate to claim her share as an acknowledged natural child.
7. **Opposition by Defendants (1953):** The defendants opposed the claim, asserting Josefa was never duly acknowledged and that her action for acknowledgment was time-barred.
8. **Trial Court Decision (1953):** The Court of First Instance of Manila dismissed the petition, holding the claim for acknowledgment was filed too late.
9. **Appeal to the Supreme Court:** The Court of Appeals certified the case to the Supreme Court, as it involved solely legal questions.
**Issues:**
1. Was Josefa Mendoza properly acknowledged as the natural daughter of Claro Bustamante under the law?
2. Was Josefa Mendoza’s action to compel recognition filed within the prescribed period?
**Court’s Decision:**
– **Acknowledgment Issue:** The Supreme Court held that Josefa had not been legally recognized as a natural daughter. Recognition under the Spanish Civil Code of 1889 required acknowledgment in a record of birth, will, public document, or final judgment. Josefa relied on a private document and acts indicative of her status, which did not meet these legal criteria.
– **Timeliness of Action:** The Supreme Court agreed with the trial court that Josefa’s action was barred due to her inaction during Claro Bustamante’s lifetime. According to Article 137 of the Spanish Civil Code of 1889, actions for acknowledgment must occur during the parent’s lifetime unless specific exceptions apply. Josefa did not meet these exceptions as she was 36 at Claro’s death, and the rediscovered document was not “previously unknown.” Moreover, even under the old Code of Civil Procedure (Act 190), any claim for acknowledgment would be prescribed ten years from Claro’s death, by 1939. Josefa’s claim, therefore, was filed too late.
**Doctrine:**
– The doctrine in this case reaffirms that recognition of a natural child must strictly adhere to the modalities specified in the governing Civil Code provisions and is time-bound under said laws (Spanish Civil Code of 1889, Articles 135, 136, 137).
**Class Notes:**
– Recognition of Natural Child: Must be by public document, will, birth record, or final judgment.
– Action to Compel Recognition: Must be filed during the parent’s lifetime unless specific exceptions apply (Spanish Civil Code Art. 137).
– Prescription of Actions: Even when exceptions apply, swift legal action is essential (max 10 years under Act 190).
**Historical Background:**
– This case arises in the context of changing legal norms on inheritance and legitimacy following the Spanish Civil Code of 1889 and introduces issues of prescribed legal timelines and the transitioning legal standards with the introduction of subsequent procedural statutes. The decisions highlight the rigid application of the Civil Code’s acknowledgment provisions and the importance of filing claims within statutory periods.
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