G.R. No. 200169 - Aguilar vs. Siasat

Petitioner Rodolfo S. Aguilar filed a civil case against respondent Edna G. Siasat regarding ownership of two parcels of land titled under Transfer Certificates of Title Nos. T-25896 and T-(15462) 1070.
The land belonged to the estate of spouses Alfredo Aguilar and Candelaria Siasat-Aguilar, who died intestate and without debts in 1983 and 1994 respectively.
Petitioner claimed to be the sole surviving heir and son of the Aguilar spouses, discovered the subject titles missing, suspected theft by the Siasat clan, and initiated actions to recover ownership documents.

Petitioner alleged that he was the legal son and sole heir, supported by school records, income tax returns, Alfredo Aguilar’s Social Security System (SSS) Form E-1 (a public instrument acknowledging petitioner as son), employment documents of Alfredo Aguilar, marriage certificate identifying the Aguilar spouses as parents, and testimonies from his wife and an aunt.
Petitioner also submitted certification explaining the destruction of local birth records covering 1945-1946, hindering his ability to present a birth certificate.
Testimonies from petitioner’s wife and aunt confirmed his filiation and recognition as sole heir.

Respondent denied petitioner’s filiation, claiming he was a stranger raised by the Aguilar spouses out of generosity.
She contended petitioner was neither a natural nor adopted child, and that the subject properties were entrusted to her by Candelaria Siasat-Aguilar (her aunt) for safekeeping.
Respondent presented an affidavit of Candelaria Siasat-Aguilar stating she had no issue and was sole heir of Alfredo Aguilar, testimonies of relatives denying petitioner’s relationship, and asserted the preexisting familial rights of Candelaria’s siblings.

The RTC ruled in favor of respondent, finding no conclusive evidence proving petitioner’s biological or legal filiation.
The court emphasized absence of petitioner’s birth certificate and the affidavit of Candelaria stating they had no issue, invalidating petitioner’s claim and dismissing his complaint for lack of legal interest.
Counterclaims for damages by respondent were also dismissed for lack of legal basis.

Petitioner appealed, arguing Article 172 of the Family Code recognizes admissions of filiation in public documents, highlighting the SSS Form E-1 as sufficient proof.
Petitioner challenged the dismissal of his evidence and the reliance on Candelaria’s affidavit which was allegedly disregarded in an earlier order.
The CA upheld the RTC ruling, discounting petitioner’s documents including school records, income tax return, marriage certificate, and SSS Form E-1, finding these insufficient as proof of filiation.
The CA held petitioner failed to meet the high standard of clear and convincing evidence to establish legitimate filiation and thus none of his claims for ownership or damages were granted.

Petitioner filed a Petition for Review on Certiorari before the Supreme Court, asserting the CA erred in disregarding the SSS Form E-1 as a public document admitting filiation under Article 172 of the Family Code.
The Petition raised a pure question of law regarding the proper application of Article 172, Sections 19 and 23 of Rule 132 of the Rules of Court relative to public documents and proof of filiation.

Whether Alfredo Aguilar’s SSS Form E-1, acknowledging petitioner as his son, constitutes sufficient proof of petitioner’s legitimate filiation under Article 172 of the Family Code.
Whether respondent can still impugn petitioner’s legitimacy given the presumption of legitimacy and applicable statutes of limitation under Articles 170 and 171 of the Family Code.
Whether petitioner, having established legitimate filiation, is entitled to mandatory injunctive relief to recover possession of the owner’s duplicate titles and damages.