Facts:

The case of Romeo S. Amurao vs. Hon. Court of Appeals and Romuel Jerome Buenaventura, decided on December 29, 1988, involves a dispute over child support stemming from the implications of paternity in illicit relationships. The petitioner, Romeo S. Amurao, was sued for support by Romuel Jerome Buenaventura, the child born from his relationship with Fe Rosario Buenaventura, a 19-year-old college student. On July 25, 1977, the trial court sought to clarify issues and promoted a conference between Amurao and the respondents. An agreement was reached, which necessitated both parties to undergo a blood-grouping test, to be administered by the National Bureau of Investigation (NBI) to determine Amurao’s paternity over Romuel. According to the terms agreed upon in a court order dated September 26, 1977, if the tests indicated that Amurao could be the father, the case would then proceed solely on the issue of required support. On the contrary, if the results were negative, the case woul

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Facts:

Background of the Case

• Romeo S. Amurao (petitioner) was sued for support by Romuel Jerome Buenaventura, a minor born of his illicit relationship with a 19-year-old college student.
• The petitioner denied paternity and refused to provide support.

Pre-Trial Proceedings and Agreement

• On July 25, 1977, during trial proceedings, the trial court held an impromptu conference in chambers with the parties and their counsels.
• The purpose was to simplify the issues by narrowing the dispute to the question of paternity.
• The parties reached an agreement which was documented in the minutes of the conference and embedded in the court’s order dated September 26, 1977.
• The agreement required both parties to submit to a blood-grouping test by the National Bureau of Investigation (NBI) for paternity determination.
• The terms were that if the test showed the child could be the petitioner’s offspring, paternity would be admitted and the trial would proceed solely on the issue of support.
• Conversely, if the test was negative, the case would be dismissed without further trial.

Evidence and Initial Court Findings

• The NBI conducted the required blood-grouping tests and submitted Report No. 77-100 on October 17, 1977.
• The report stated that “the said child… is a possible offspring of the alleged father Romeo Amurao with Fe Rosario Buenaventura as the natural mother.”
• On September 26, 1978, the petitioner filed a motion for reconsideration of the trial court’s September 26, 1977 order, which was subsequently denied.

Subsequent Proceedings and Trial Developments

• A petition for certiorari was filed by the petitioner (G.R. No. 51407) and later denied on May 4, 1980.
• A motion to declare the petitioner in contempt of court was filed by the minor for failure to pay support pendente lite.
• At the ensuing hearing, evidence regarding the petitioner’s capacity to give support was presented by both sides.
• The case was set for trial on July 8, 1983, to present additional evidence on the main case.
• The petitioner and his counsel failed to appear, leading the trial court to declare the case submitted for decision.
• On August 8, 1985, the trial court rendered judgment ordering the petitioner to pay support at P500 per month, along with attorney’s fees and costs.
• The petitioner appealed to the Court of Appeals, which issued a judgment on March 7, 1988, modifying the support obligation:
• The amount of support was increased to P1,500 per month.
• The petitioner was ordered to pay support pendente lite of P200 in arrears from October 1978 until the appeal’s termination.

Issues Raised on Review

• The petitioner challenged the Court of Appeals’ ruling on several grounds including:
• The finding that he had admitted paternity under the trial court’s order, hence binding him to support his child.
• The reliance on evidence presented during the contempt motion hearing to decide on the merits of the main support case.
• The increase in the amount of support fixed by the trial court.
• The application of Article 290 of the Civil Code instead of using Articles 290 and 297 together.

Issue:

Whether the petitioner’s alleged admission of paternity, as reflected in his conduct and the trial court’s order dated September 26, 1977, legally bound him to pay support to the minor.

• Was the determination of paternity based solely on the blood-grouping test and parties’ agreement legally conclusive?

Whether the trial court was justified in relying on the evidence presented at the hearing of the contempt motion to determine the petitioner’s capacity and obligation to provide support in the main case.

• Did the petitioner's failure to appear at the July 8, 1983, hearing constitute a waiver of his right to adduce further evidence?

Whether the Court of Appeals correctly increased the amount of support from P500 to P1,500 per month, also considering the retroactive application of support pendente lite.

• Is such an increase substantiated by the evidence and the evolving circumstances of the child’s needs?

• Whether the application of Article 290 alone, as opposed to Articles 290 and 297 of the Civil Code, was appropriate in determining the petitioner’s support obligations.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)