Case Digest (G.R. No. 211034)
Facts:
- Two consolidated petitions were filed by Mario Chiong Bernardo and the heirs of the late Jose Chiong, along with Josefina L. Bernardo, Leticia L. Bernardo, Felix Bernardo, and Marcelo San Juan as petitioners.
- Respondents include Jose C. Fernando and others.
- The petitions challenged the Court of Appeals (CA) decision dated November 7, 2013, which reversed the Regional Trial Court's (RTC) ruling from November 10, 2008.
- The RTC had declared the respondents' Affidavit of Identity null and void and ordered the reconveyance of five parcels of land originally covered by Transfer Certificate of Title (TCT) Nos. RT-26575, RT-26580, RT-26578, RT-26577, and RT-26576.
- Jose Chiong executed a Deed of Donation in 1925, bequeathing the properties to Jose Chiong Fernando, the respondents' predecessor-in-interest.
- In 2002, the respondents executed an Affidavit of Identity claiming to be legal heirs, leading to the cancellation of original titles and transfer to their names.
- Mario filed a complaint for Annulment, Reconveyance, and Accounting in 2003, while others filed for Recovery of Ownership, Declaration of Heirship, and Partition.
- The RTC ruled in favor of the petitioners, establishing Mario's mother, Barbara Chiong, as a legitimate child of Jose Chiong, making them direct heirs.
- The CA reversed the RTC's decision, prompting the current petitions.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the consolidated petitions and affirmed the CA's decision.
- The Court concluded that the petitioners failed to establish their claim to...(Unlock)
Ratio:
- The Court highlighted that the burden of proof rests with the petitioners to demonstrate legitimate filiation.
- Article 172 of the Family Code of the Philippines outlines the methods for proving filiation, including a birth record or a public document acknowledging legitimate filiation.
- The petitioners did not provide adequate evidence to prove Barbara Chiong's legitimacy as a child of Jose Chiong.
- The birth certificate lacked proof of paternity, as there was no evidence of Jose Chiong's involvement in its preparation.
- The absence of a marriage certific...continue reading
Case Digest (G.R. No. 211034)
Facts:
The case involves two consolidated petitions filed by Mario Chiong Bernardo, representing himself and the heirs of the late Jose Chiong, and by Josefina L. Bernardo, Leticia L. Bernardo, Felix Bernardo, and Marcelo San Juan, collectively referred to as petitioners. The respondents are Jose C. Fernando, Lilia C. Fernando, Noemi Fernando Molina, Cynthia C. Fernando, Aida Fernando Pointdexter, and Elsa Fernando. The petitions were filed against the decision of the Court of Appeals (CA) dated November 7, 2013, which reversed the Regional Trial Court's (RTC) Consolidated Decision dated November 10, 2008. The RTC had ruled in favor of the petitioners, declaring the Affidavit of Identity executed by the respondents as null and void and ordering the reconveyance of five parcels of land left by the late Jose Chiong.
The subject properties were originally covered by Transfer Certificate of Title (TCT) Nos. RT-26575, RT-26580, RT-26578, RT-26577, and RT-26576. On May 18, 1925, Jose Chiong executed a Deed of Donation bequeathing these properties to Jose Chiong Fernando, the predecessor-in-interest of the respondents. In 2002, the respondents executed an Affidavit of Identity claiming to be the legal heirs of Jose Chiong, which led to the cancellation of the original titles and their transfer to the respondents' names.
Mario filed a complaint for Annulment, Reconveyance, and Accounting on September 25, 2003, while Josefina and others filed a separate complaint for Recovery of Ownership and Possession, Declaration of Heirship, ...