G.R. No. 206647 - Abella vs. Cabanero

Petitioner Richelle P. Abella filed on behalf of her minor daughter, Marl Jhorylle Abella, an action for support against respondent Policarpio CabaAero before RTC Branch 12, San Jose, Antique (Civil Case No. 2005-4-3496).
Richelle alleged that respondent, her mother’s relative whom she treated as an uncle, repeatedly sexually abused her from 2000 to 2002, resulting in the birth of her daughter on August 21, 2002.

Richelle first filed criminal complaints for rape and, later, for child abuse under RA 7610; both were dismissed.
On April 22, 2005, she filed a Complaint for Support praying for ₱3,000 monthly allowance, alleging respondent was the child’s father. Respondent denied any sexual relations or paternity.
After pre-trial, Richelle’s motion to present evidence ex parte was granted. She testified to the abuse dates (July 25, 2000; September 10, 2000; February 8, 2002), birth of the child, and her certainty of respondent’s paternity.
On March 19, 2007, RTC dismissed the Complaint without prejudice for failure to implead the minor child as plaintiff.
On August 25, 2011, the Court of Appeals affirmed dismissal, not for non-joinder, but because filiation was unestablished; held that petitioner should have first instituted filiation proceedings. A January 15, 2013 CA resolution denied reconsideration.
Petitioner filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court.

Must separate filiation (compulsory recognition) proceedings be instituted and resolved in favor of the child’s paternity claim before an action for support can prosper?
Did the Court of Appeals err in dismissing the support action instead of remanding for integrated determination of filiation and support?