G.R. No. 137674 - Go Kim Huy vs. Go Kim Huy

Bonifacio Go Kim, the decedent, died on February 26, 1974.
Petitioner William Go Kim Huy, formerly known as Gaw Piak, claims to be a legitimate son of Bonifacio Go Kim.
William’s arrival in Manila at age six (May 1933) and subsequent schooling (Far Eastern University) and employment history (stock brokerage, import business, plastic manufacturing).
Bonifacio Go Kim was an alien engaged in selling bakery supplies and grocery items prior to petitioner's arrival.

Respondent Santiago Go Kim Huy, said to be the only son of Bonifacio, along with his family members, are involved in managing and holding the decedent’s estate.
The business started by Bonifacio expanded, forming a partnership in 1947 under the name “Bonifacio Go Kim & Son”, later amended to “Bonifacio Go Kim & Sons” to meet business registration requirements.
The accumulated business assets include several properties and businesses that are now sources of controversy regarding their rightful ownership.

Petitioner claims that Bonifacio recognized him as his son by registering him as one of his children.
Key documentary evidence presented by petitioner included:

An application for alien registration of Bonifacio (Exhibit "B") indicating two children, naming petitioner and Santiago.
The Alien Certificate of Registration (Exhibit "EEE") and Landing Certificates (Exhibits "FFF" and "M") supporting his arrival and identity changes.
Additional document evidences (Exhibits "K") concerning the borrowing of immigration documents.

These documents were later cancelled by a resolution of the Bureau of Immigration and Deportation (BID) (Exhibit "I") which ordered corrections in the immigration records.

A long-running legal controversy began on June 18, 1980 when petitioner filed a complaint to declare the properties held by respondent Santiago Go Kim Huy and other family members as part of Bonifacio Go Kim’s estate and to compel an accounting.
Various motions and orders ensued:

The trial court initially granted a change of name for petitioner (from Gaw Piak to Go Kim Huy) on April 20, 1964.
The trial court later ruled on the issue of property rights against petitioner’s claim, particularly regarding the rightful share in the estate.
The Regional Trial Court had issued an Order cancelling the lis pendens on property titles (June 2, 1986), which was subsequently reversed by the Court of Appeals on April 15, 1988.

The BID’s resolution dated May 15, 1985, cancelled its prior certification and clarified that petitioner was not a son of Bonifacio.
Petitioner’s subsequent special civil action for certiorari in G.R. No. 78887 was dismissed on August 22, 1988 for lack of demonstration of grave abuse of discretion.
Records of the case were lost in a fire in Quezon City Hall (June 11, 1988), leading to a petition for reconstitution of records on May 15, 1990.
The trial court eventually dismissed the complaint for insufficiency of evidence on February 16, 1996, and imposed a P200,000.00 award for moral damages against petitioner.
The Court of Appeals affirmed the trial court’s decision on November 12, 1998, which the petitioner later sought to nullify on multiple grounds.

Failure by the Court of Appeals to find that petitioner is the son of Bonifacio due to lack of evidence to establish filiation.
Alleged disregard by the Court of Appeals of unchallenged sworn declarations affirming petitioner’s filiation and undue reliance on the cancelled BID certifications.
The petitioner's contention that Bonifacio Go Kim had a son by the name Go Kim Huy and that he himself is that son, thus entitling him to a share in the decedent’s estate.
The claim that respondents should also be held liable for damages related to the dispute.

Whether petitioner has sufficiently proven, by clear and convincing evidence, his claim of legitimate filiation with the decedent, Bonifacio Go Kim.

Did petitioner adduce admissible and legally effective documentary evidence, such as an official record of birth or an instrument indicating filiation?
Does the cancellation of BID certifications nullify petitioner’s evidence of filiation?

Relying on the provisions of the Family Code (although the applicable law at the time was the Civil Code) in dismissing petitioner’s claim.
Failing to give weight to the unchallenged sworn declarations and other documents that the petitioner offered to prove his relationship with the decedent.
Not recognizing petitioner’s claim to a share in the decedent’s properties, which are held under the Torrens System, and which should benefit a legitimate heir.

Whether the award for moral damages should have been imposed on petitioner and, if so, whether the quantum of damages is justified by the facts and evidence, particularly in view of the delays and the conduct of both parties.