Title
Bartolome vs. Bartolome
Case
G.R. No. L-23661
Decision Date
Dec 20, 1967
A dispute over Venancio Bartolome's estate involving claims of legitimacy and acknowledgment by alleged natural children, dismissed due to lack of evidence, jurisdiction, and time-barred claims.
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Case Digest (G.R. No. L-23661)

Facts:

  1. Background of the Case:

    • Venancio Bartolome died intestate on August 4, 1948.
    • On November 25, 1953, Flaviana Fajardo (widow) and Justo Bartolome (alleged only legitimate son) executed a deed of extrajudicial partition, dividing three houses in Sampaloc, Manila, equally between them.
  2. Jose Manangol Bartolome's Claim:

    • On July 8, 1955, Jose Manangol Bartolome filed a petition in the Court of First Instance of Manila (Special Proceeding No. 26785), claiming to be a legitimate son of Venancio Bartolome and Flaviana Fajardo.
    • He sought to nullify the extrajudicial partition, appoint himself as administrator, and settle the estate.
    • The court dismissed his petition, ruling that Jose was an illegitimate son of Venancio Bartolome and Sotera (Emilia) Pangilinan. This decision was affirmed by the Court of Appeals on March 30, 1959.
  3. Death of Flaviana Fajardo and Distribution of Estate:

    • Flaviana Fajardo died on May 24, 1959.
    • On December 23, 1959, the Court of First Instance approved the project of partition, distributing Venancio Bartolome's estate equally between Flaviana Fajardo's estate and Justo Bartolome.
    • On January 5, 1960, Justo Bartolome executed an affidavit adjudicating the entire estate (cash and houses) to himself.
  4. Plaintiffs' Allegations:

    • On November 4, 1963, Jose Manangol Bartolome, Antonio Bartolome, and Adalaida Bartolome (plaintiffs) filed a complaint against Justo Bartolome (defendant).
    • Plaintiffs Antonio and Adalaida claimed to be children of Venancio Bartolome and Francisca Untalan, asserting they were acknowledged natural children.
    • They alleged that Justo Bartolome and Flaviana Fajardo conspired to deprive them of their share in the estate by misrepresenting Venancio's marital status.
    • Plaintiffs sought a declaration of their status as acknowledged natural children, nullification of the estate distribution, and conveyance of one-fourth of the estate to each plaintiff.
  5. Lower Court's Decision:

    • The Court of First Instance dismissed the complaint, citing:
      a) No cause of action.
      b) Lack of jurisdiction over the subject matter.
      c) The cause of action was barred by the statute of limitations.

Issue:

  1. Whether the complaint states a valid cause of action.
  2. Whether the Court of First Instance had jurisdiction over the case.
  3. Whether the plaintiffs' cause of action is barred by the statute of limitations.
  4. Whether the plaintiffs are entitled to a share in Venancio Bartolome's estate as acknowledged natural children.

Ruling:

The Supreme Court affirmed the lower court's dismissal of the complaint, holding that:

  1. The complaint failed to establish that Venancio Bartolome and Flaviana Fajardo were not married. The absence of their marriage in the Civil Registrar's indices does not disprove their marital status, especially given their long cohabitation as husband and wife, which creates a presumption of marriage.
  2. The plaintiffs' continuous possession of the status of acknowledged natural children was insufficient to confer legal status as acknowledged natural children under the Civil Code of Spain (applicable at the time of Venancio's death).
  3. The action for compulsory recognition of natural children must be filed during the lifetime of the presumed parents, except under specific exceptions, none of which applied here.
  4. The Court of First Instance lacked jurisdiction over the case, as jurisdiction over acknowledgment of natural children was vested exclusively in the Court of Juvenile and Domestic Relations.
  5. Jose Manangol Bartolome's claim was barred by the prior decision in Special Proceeding No. 26785, which declared him an illegitimate son of Venancio Bartolome and Sotera Pangilinan.

Ratio:

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