G.R. No. 170115 - Province of Cebu vs. Heirs of Morales

Federica Aballe, acting in her own behalf and on behalf of her minor sons, Rodolfo Santiago and June Jose Santiago, instituted an action for support, successional rights, and moral damages against Fortunato Santiago.
The relationship between Federica Aballe and Fortunato Santiago was characterized by a common-law marriage beginning in 1947 in Toboso, Negros Occidental.
During this period, the defendant was leasing Hacienda Fuentes, and the plaintiff’s father was employed as a laborer under him.

Rodolfo Santiago, the first child, was born on February 5, 1948, evidenced by a baptismal certificate issued by the Parish Priest of Sagay, Negros Occidental.
June Jose Santiago, the second child, was born on June 4, 1953, as shown by a baptismal certificate issued by Fr. Fortich of San Sebastian Cathedral in Bacolod City.

The plaintiff testified that during the defendant’s frequent commutes between Bacolod City and Toboso, he would send her various notes (documentary evidence identified as Exhibits C through K).
These notes were introduced to establish not only the existence of a relationship but also to serve as evidence of paternity and the defendant’s support for the children.

After the birth of the second child, Federica Aballe discovered that the defendant was married.
As a result, she separated from him and took up residence in a house purchased by the defendant for her in January 1957, now located in Barangay Santo Niño, Bacolod City.

Fortunato Santiago denied that the minor children, Rodolfo and June Jose, were his offspring, disputing the claim of illegitimate paternity.
He also refuted the authenticity and authorship of the notes (Exhibits C through K), and denied any acknowledgment or supportive acts toward the minors.

At trial, the lower court dismissed the claims for support, successional rights under Article 287 of the Civil Code, as well as the claim for moral damages under Article 21 of the Civil Code, based on the insufficiency of the evidence presented by the plaintiff.
The trial judge scrutinized the documentary evidence—including the baptismal certificates, envelopes, and handwritten notes—finding them unreliable or inadmissible.
The dismissal was further reinforced by the plaintiff’s delay in filing the complaint (nearly seven years after discovering the defendant’s marital status) and the defendant’s consistent denials.

As indigents, the plaintiffs directly appealed to the appellate court, alleging two primary errors committed by the trial court:

Failure to hold that the defendant’s uncontradicted material evidence should be deemed impliedly admitted.
Failure to award moral damages, support for the minors, and attorney’s fees.

Whether the trial court erred in not considering that the uncontested material evidence presented by the plaintiffs should be deemed impliedly admitted by the defendant.
Whether the failure to award moral damages, support for the minors, and attorney’s fees constituted an error on the part of the trial court.
Whether the documentary evidence, including the baptismal certificates, handwritten notes, and other exhibits, was sufficient to establish the paternity of the minors and the existence of a common-law marriage.
Whether the significant delay in filing the complaint (almost seven years after discovering the defendant’s marital status) affected the validity of the claims for support and successional rights.