Facts:

On March 7, 1983, a complaint for compulsory recognition and enforcement of successional rights was filed before Branch 30 of the Regional Trial Court of Manila. The complaint was initiated by minors Antonia F. Aruego and Evelyn F. Aruego, represented by their mother Luz M. Fabian. Named as defendants were Jose E. Aruego, Jr., and the five minor children of the deceased Gloria A. Torres, represented by their father Justo P. Torres, Jr., who are the petitioners in this case. The complaint alleged that the late Jose M. Aruego, Sr., who was a married man, engaged in an amorous relationship with Luz M. Fabian starting in 1959 until his death on March 30, 1982. As a result of this relationship, Antonia was born on October 5, 1962, and Evelyn on September 3, 1963. The plaintiffs prayed for an order to recognize them as the illegitimate children of Jose M. Aruego, Sr. They sought to compel the defendants to acknowledge them as compulsory heirs and to determine their respective shares i

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Facts:

Background of the Case

• A Complaint for Compulsory Recognition and Enforcement of Successional Rights was filed on March 7, 1983, before Branch 30 of the Regional Trial Court of Manila.
• The complaint was brought by the minors, Antonia F. Aruego (private respondent) and her alleged sister, Evelyn F. Aruego, represented by their mother and natural guardian, Luz M. Fabian.
• Named defendants included Jose E. Aruego, Jr. and the five minor children of the deceased Gloria A. Torres, represented by their father and natural guardian, Justo P. Torres, Jr., now the petitioners in this case.

Allegations in the Complaint

• The complaint alleged that the late Jose M. Aruego, Sr., though married, had an amorous relationship with Luz M. Fabian from 1959 until his death on March 30, 1982.
• Out of this relationship were born Antonia F. Aruego (October 5, 1962) and Evelyn F. Aruego (September 3, 1963).
• The plaintiffs contended that Jose M. Aruego, Sr. had openly and continuously recognized these children as his own, as evidenced by various paternal acts, including:
• Regular support and educational expenses.
• Allowance to use his surname.
• Payment of maternal bills and baptismal expenses.
• Inclusion in family events and other manifestations of paternal care.
• The relief sought was to have the plaintiffs declared as the illegitimate children of Jose M. Aruego, Sr., compel their recognition as compulsory heirs, and determine their respective share in the deceased’s estate.

Lower Court Proceedings and Decision

• After trial, the lower court rendered judgment on June 15, 1992, which among other rulings:
• Declared Antonia Aruego as the illegitimate daughter of Jose M. Aruego, Sr. and Luz M. Fabian.
• Denied the recognition of Evelyn F. Aruego as an illegitimate daughter.
• Ordered that the estate of the deceased be divided accordingly, with Antonia entitled to an additional share equal to one-twelfth of the share of the legitimate children.
• Directed the defendants to recognize Antonia’s status and deliver her share of the estate.
• The lower court also ordered the payment of attorney’s fees and costs against the defendants.

Post-Judgment Motions and Controversies

• Petitioners filed a Motion for Partial Reconsideration alleging that the trial court lost jurisdiction because of the effect of Executive Order No. 209 (as amended by Executive Order No. 227), otherwise known as the Family Code of the Philippines, which took effect on August 3, 1988.
• The lower court denied the motion on January 14, 1993, and refused an appeal on the grounds of the appeal being untimely filed.
• Thereafter, petitioners secured a Petition for Prohibition and Certiorari, with a Prayer for a Writ of Preliminary Injunction, before the Court of Appeals, which was dismissed for lack of merit on August 31, 1993.
• A subsequent Motion for Reconsideration before the Court of Appeals was also denied on October 13, 1993.

Legal Issue on the Applicable Law

• The private respondent’s action for compulsory recognition was originally filed under Book I, Title VIII of the Civil Code on PERSONS, specifically Article 285, which governs the recognition of illegitimate children.
• Petitioners contended that with the enactment of the New Family Code on August 3, 1988, the complaint should be subjected to the prescription rules under Article 175, paragraph 2 of the Family Code, which mandates that an action based on the “open and continuous possession of the status of an illegitimate child” must be filed during the lifetime of the alleged parent.
• Petitioners further argued that, because the complaint was filed almost a year after the death of the presumed father, it had prescribed under the new rule.

Substantive Legal Conflict

• The pivotal issue involved whether the provisions of the Family Code should be applied retroactively to a cause of action that was filed under the Civil Code regime.
• The petitioners argued that applying the Family Code would prejudice the vested rights of private respondent by barring her recovery under Article 285 of the Civil Code.
• The Court examined previous jurisprudence, such as the Uygungco and Tayag cases, which addressed the retroactive application of new laws and the protection of vested rights once a cause of action has attached.

Issue:

• Whether the provisions of the Family Code (particularly Article 175, paragraph 2) should be applied in a case in which the complaint was filed prior to its effectivity, thereby potentially barring the action for compulsory recognition.
• Whether the trial court maintained its jurisdiction over the case despite the enactment of Executive Order No. 209 (the Family Code) after the filing of the complaint.
• Whether the application of a new legal regime (the Family Code) would prejudice or impair the vested rights of the private respondent, who had her cause of action established under the Civil Code.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)