G.R. No. 67301 - Bala vs. Martinez

On September 1, 1955, Lilia Juana Barles, Maria Estrella Barles, and Remedios Baeles, all of legal age, filed a petition with the Court of First Instance of Manila.
The petition alleged that they were the illegitimate (spurious) children of defendant Alfonso Ponce Enrile and Genoveva Barles, their natural mother, with whom the defendant cohabited when they were conceived and born.
The plaintiffs sought the judicial recognition of their filiation along with a claim for moral damages.

Defendant Alfonso Ponce Enrile opposed the petition by filing a motion to dismiss on two principal grounds:

The complaint did not state a valid cause of action.
The action had already prescribed pursuant to the applicable prescription rules.

The court deferred action on the motion pending the trial, remarking that the grounds for the motion were not indubitable.
Subsequently, the defendant filed his answer, and the case proceeded to trial.

While the case was still pending, the Juvenile and Domestic Relations Court was organized under Republic Act No. 1401.
The case was transferred to the newly constituted court, where the trial continued.
On June 1, 1957, the Juvenile and Domestic Relations Court rendered a decision dismissing the complaint.

The decision was rendered without reaching the merits of the case.
The court held that although the complaint might state a valid cause of action based on the evidence, the action was barred by prescription.
The court determined that the cause of action accrued from the birth of the plaintiffs and that the action should have been filed within ten years from accrual—or more strictly, within two years after the attainment of majority as required by Section 45 of the Code of Civil Procedure.

After the decision of the Juvenile and Domestic Relations Court, plaintiffs directly appealed to the Supreme Court.
The appeals included contention regarding the proper time when the cause of action accrues and whether the prescription period should indeed bar the action.
The appeal was later supplemented by a motion for reconsideration by the defendant-appellee, which challenged the court’s interpretation of the applicable prescription rules.

Whether the cause of action for investigating spurious paternity accrues from the moment of birth or from the time the right to commence the action actually arises.
Whether the prescription period applicable to the action for recognition of natural paternity under Article 285 of the new Civil Code should similarly apply to the investigation of spurious paternity.
If the plaintiffs, who were born before the effectivity of the new Civil Code, may now avail themselves of the provisions of the new Civil Code for their action.
Whether the appellate courts erred in dismissing the complaint solely on the ground of prescription without allowing consideration of the substantive validity of the cause of action.