Case Digest (G.R. No. 162571) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Agustin v. Court of Appeals, G.R. No. 162571, decided on June 15, 2005, petitioner Arnel L. Agustin was sued by Fe Angela Prollamante and her minor son Martin in the RTC of Quezon City (Civil Case No. Q-02-46301) on March 5, 2002 for support and support pendente lite. Fe alleged that she and Arnel entered into an intimate relationship in 1992, resulting in her pregnancy on November 10, 1999, and the birth of Martin on August 11, 2000, whose birth certificate Arnel purportedly signed. After initially covering prenatal and hospital expenses, Arnel later denied paternity, questioned the authenticity of the birth certificate and its community tax certificate, suggested adoption, and refused all support. Aggravating the conflict, Fe accused Arnel of injuring her on January 19, 2001, when his van door struck her leg. In defense, Arnel invoked that their last intimacy occurred in 1998, pointed to Fe’s other lovers, and filed criminal charges for falsification of documents and a sep Case Digest (G.R. No. 162571) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of Parties and Relationship
- In 1992, petitioner Arnel L. Agustin courted Fe Angela Prollamante; they entered into an intimate, on‐and‐off relationship from 1993 to 1998.
- Fe allegedly conceived Martin on her 34th birthday (November 10, 1999) and gave birth to him out of wedlock on August 11, 2000 at Capitol Medical Hospital, with a birth certificate purportedly signed by Arnel.
- Post-Birth Events and Dispute
- Arnel initially paid prenatal and hospital expenses but then refused to support Martin, suggested adoption, and denied paternity; an incident occurred on January 19, 2001 when Arnel’s van door struck Fe’s leg.
- In July 2001, Fe was diagnosed with leukemia and commenced chemotherapy; on March 5, 2002, Fe and Martin filed a support complaint (RTC, Quezon City Branch 106, Civil Case No. Q-02-46301).
- Trial Court Proceedings
- Arnel’s Defenses and Motions
- Denied he sired Martin, alleging affair ended in 1998 and had secret lover; claimed signature on birth certificate and CTC were forged; invoked right against self-incrimination.
- Moved to dismiss complaint for lack of cause of action, asserting unrecognized illegitimate child cannot claim support; filed criminal and civil petitions to cancel his alleged acknowledgment and proved forgery via PNP laboratory certification.
- Orders of Lower Courts
- On February 5, 2003, RTC denied Arnel’s motion to dismiss and, under Rule 28 of the Rules of Court, directed DNA paternity testing at respondents’ expense.
- On January 28, 2004, the Court of Appeals (CA) in CA-G.R. SP No. 80961 affirmed both the trial court’s resolution denying dismissal and its order for DNA testing; a March 8, 2004 CA resolution likewise affirmed.
Issues:
- Conversion of Action
- Whether the order for DNA testing and the CA’s decision effectively converted the complaint for support into a petition for recognition of paternity.
- Whether, under the Civil Code (Arts. 265, 283) and Rules of Court (Rule 105, Sec. 1), an unrecognized illegitimate child must first file a separate recognition suit before claiming support.
- Constitutionality of DNA Testing
- Whether ordering compulsory DNA paternity testing violates petitioner’s right against self-incrimination (Art. III, Secs. 12 and 17, 1987 Constitution).
- Whether such testing infringes his right to privacy under the Constitution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)