Facts:

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 seeking recognition of their paternal affiliation and damages for moral injury. They claimed to be the illegitimate children of the defendant, Alfonso Ponce Enrile, and their natural mother, Genoveva Barles, with whom Enrile cohabited at the time of their conception and birth. Instead of responding to the complaint, Enrile filed a motion to dismiss, arguing that the complaint failed to state a cause of action and that any potential claim had already prescribed. The court deferred action on the motion until after the trial, believing the grounds for dismissal were not indubitable. Subsequently, Enrile filed an answer, and the case was transferred to the newly established Juvenile and Domestic Relations Court under Republic Act No. 1401. On June 1, 1957, this court dismissed the complaint, ruling that while the plain...

Facts:

Procedural Background

• On September 1, 1955, Lilia Juana Barles, Maria Estrella Barles, and Remedios Baeles, all of legal age, filed a petition before the Court of First Instance of Manila.
• The petition was for the recognition of paternal filiation with a claim for moral damages, alleging that they are illegitimate children of defendant Alfonso Ponce Enrile, conceived and born during his cohabitation with their natural mother, Genoveva Barles.
• Instead of filing an answer at the outset, the defendant moved to dismiss the complaint, arguing that it did not state a cause of action and that, even if it did, the action was already prescribed.

Case Development and Transfer

• Although the dismissal motion was presented, the court deferred ruling on it during the trial because the grounds for dismissal did not appear indubitable at that time.
• The defendant subsequently filed his answer.
• In the course of the proceedings, the case was transferred from the Court of First Instance to the newly organized Juvenile and Domestic Relations Court under Republic Act No. 1401, where the trial continued.

Decision of the Juvenile and Domestic Relations Court

• On June 1, 1957, the Juvenile and Domestic Relations Court rendered a decision dismissing the complaint on the ground of prescription.
• The court held that although the evidence could justify the recognition of a valid cause of action, the action was barred by prescription because it had not been filed within the prescribed period.
• It was determined that the cause of action accrued from the plaintiffs’ birth and, pursuant to Section 44 of the old Code of Civil Procedure (and Section 45 for minors), the action should have been commenced within two years after attaining majority.

Appeal and Subsequent Proceedings

• The plaintiffs, dissatisfied with the dismissal based on prescription, appealed directly to the Supreme Court.
• The Supreme Court found that the lower court misapplied the law in determining the accrual of the cause of action.
• The central contention was that plaintiffs’ action, being authorized under Article 289 of the new Civil Code for the investigation of spurious paternity, should not be construed as prescribed when filed during the lifetime of the alleged parent.

Issue:

Whether the lower court erred in holding that the plaintiffs’ cause of action accrued from birth, thereby subjecting the action to a prescription period commencing from that time.

• Did the evidence and legal grounds justify the recognition of a valid cause of action despite the arguments on prescription?
• Is it appropriate to apply the prescription period, as outlined in the old Code of Civil Procedure, to an action now governed by the new Civil Code?

Whether the action for the investigation of spurious paternity should be analogized to the action for recognition of natural children under Article 285 of the new Civil Code.

• Does the similar nature of both actions justify the imposition of the same time limitations?
• Should the period prescribed for recognition of natural children also apply to spurious children when the law does not specify a distinct period?

The proper point in time when the right to commence the action arises for filing the complaint.

• Is the right to file an action that seeks to investigate paternity effective from birth or from the moment the cause of action accrues as per the new Civil Code provisions?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)