G.R. No. 124814 - Cabatania vs. Court of Appeals

The controversy arose from a petition for recognition and support filed by Florencia Regodos on behalf of her minor son, Camelo Regodos, against petitioner Camelo Cabatania.
The Regional Trial Court of Cadiz City, Branch 60, in Spec. Proc. No. 88-C compelled petitioner Cabatania to acknowledge Camelo Regodos as his illegitimate son and provide support in the amount of ₱500 per month.
The Court of Appeals affirmed the RTC decision in CA-G.R. 36708, which was later challenged on certiorari.

Testified that she was the mother of the child born on September 9, 1982, and that she supported him.
Recounted events that began in early 1981 when her husband abandoned her, leading her to find employment as a household help.
Stated that on January 2, 1982, while working as a maid in Bacolod City at the Visayan Motel, petitioner Cabatania had sexual intercourse with her and promised support if she became pregnant.
Claimed that the sexual act was repeated in March 1982 in San Carlos City and that she discovered her pregnancy 27 days later.
Gave birth to Camelo Regodos on September 9, 1982, with assistance from a hilot in her aunt’s house in Tiglawigan, Cadiz City.
Misrepresented herself as a widow in her petition, although her husband was actually alive.

Identified himself as a sugar planter and businessman who hired Florencia as a servant around December 1981.
Claimed that during her employment, Florencia typically went home in the afternoon to see her husband and returned the following morning.
Stated that issues arose with his wife, leading Florencia to be permitted to leave the household.
Recounted a separate incident during New Year’s Eve in Cadiz City when he met Florencia on board a bus bound for San Carlos City, subsequently taking her for dinner and lending her money.
Alleged that during sexual intercourse in San Carlos City, he felt something unusual, and upon inquiry, Florencia mentioned she was already pregnant by her husband.
Denied having taken her to Bacolod City, checked in at the Visayan Motel, or renting a house for her in Singcang, Bacolod City.

The trial court gave substantial weight to Florencia’s testimony and the personal appearance of the child as evidence of paternity.
Documentary evidence such as the child’s birth and baptismal certificates were produced by private respondent but were scrutinized regarding their evidentiary value.
The RTC concluded that, based on the presented evidence, there could be no doubt regarding the child’s paternity.
The Court of Appeals upheld the RTC’s findings, dismissing the misrepresentation regarding Florencia’s marital status as a minor issue in the overall testimony.

Petitioner Cabatania alleged errors in the application of Article 283 of the Civil Code on compulsory recognition and award of support.
Contended that the decision was based on evidence that unduly favored respondent Camelo Regodos, particularly the credibility of Florencia’s testimony.

The petition for review on certiorari was filed under Rule 45 of the Rules of Court.
Petitioner argued that the factual findings of the lower courts were either manifestly mistaken or based on misapprehensions of fact and evidence, which the Supreme Court could review under the exceptions provided by law.

Whether the trial court erred in adopting Florencia Regodos’ testimony and the personal appearance of the child as conclusive evidence of paternity despite her misrepresentation regarding her marital status.
Whether the Court of Appeals misapplied Article 283 of the Civil Code in ordering the compulsory recognition of Camelo Regodos and the award of support.
Whether the documentary evidence (birth and baptismal certificates) was sufficient and admissible to establish paternity, considering that such documents were prepared without petitioner Cabatania’s participation.
Whether the factual findings supporting the imputation of paternity were beyond review, or if exceptions warranted a re-examination by the Supreme Court due to grave abuse of discretion or misapprehension of the evidence.