Case Digest (G.R. No. 1884)
Facts:
In the case of Presentacion Infante, Guardian of the Minor Child Manuela Infante, Plaintiff and Appellee, vs. Manuel T. Figueras, Defendant and Appellant, decided on September 7, 1905 (G.R. No. 1884), the plaintiff, Presentacion Infante, filed a lawsuit against Manuel T. Figueras, claiming that he was the father of her daughter, Manuela Infante, who was born on May 29, 1901. Presentacion sought to compel Figueras to recognize Manuela as his natural child. The basis for her complaint relied on paragraph 2 of Article 135 of the Civil Code, which allows for recognition under certain conditions. Figueras denied the allegations made against him. During the trial, several witnesses were allowed to testify, despite the defendant's objections, including Presentacion's mother, Pilar Chavez, and the child's wet nurse, Natividad Coronada de la Cruz, who both claimed that Figueras was the father. The lower court ultimately ruled against Figueras, which prompted him to appeal th
Case Digest (G.R. No. 1884)
Facts:
- Parties Involved
- Plaintiff and Appellee: Presentacion Infante, acting as guardian of her minor daughter, Manuela Infante.
- Defendant and Appellant: Manuel T. Figueras.
- Minor Child: Manuela Infante, whose paternity is in dispute.
- Legal Background and Statutory Framework
- Article 135 of the Civil Code
- Paragraph 1 requires a document in the handwriting of the alleged father, expressly recognizing his paternity.
- Paragraph 2 requires that the child be in the continuous possession of the state of a natural child, justified by acts of the father or his family.
- Exceptions are noted in cases of violation, estupro, or rapto, which fall under provisions of the Penal Code.
- Law of Bases (May 11, 1888)
- Restricts the investigation of paternity to either cases of criminal offense or when there is a written instrument of recognition by the father.
- Permits the investigation of maternity, but does not extend a similar latitude for paternity as noted in Article 135.
- Preparatory Commission to the Civil Code
- Provided that recognition of a natural child must be manifested either jointly or separately by the father and mother.
- Established that separate recognition must be evidenced by a record of birth, a will, or another public document, thereby limiting extraneous evidence.
- Procedural Posture and Evidence Admitted
- The Action Initiated
- Presentacion Infante filed the case seeking to compel Manuel T. Figueras to recognize Manuela as his natural daughter under paragraph 2 of Article 135.
- The basis of the complaint was the alleged continuous possession of the status of a natural child.
- Evidence Presented at Trial
- Testimonies from:
- Pilar Chavez, the grandmother, who testified about the relations between defendant and Presentacion Infante prior to the birth of the child.
- Documentary Evidence
- Twenty-four letters signed by the defendant and addressed to the mother were admitted.
- Defendant’s Position
- Denial of all allegations concerning the paternity of Manuela.
- Objection and exception on the admissibility of the evidence involving witness testimonies and the letters.
- Lower Court’s Ruling
- The lower court rendered judgment against the defendant, ruling in favor of the plaintiff based on the admissible evidence.
- Contentious Points Regarding Evidence
- The admissibility of evidence regarding the actual paternity (relationship) and its influence on the status of continuous possession as a natural child.
- Whether the evidence, particularly that which suggests the defendant’s conduct (sending money and medicine to the mother), can be used to prove possession of the status of a natural child under the strict guidelines of Article 135.
- The interplay between the requirement of a written recognition or continuous state of possession and the introduction of extraneous evidence aiming to demonstrate actual paternity.
Issues:
- Admissibility of Evidence
- Whether evidence tending to show the actual paternity of the child – such as testimonies regarding the prior relations between the parties and the defendant’s letters to the mother – is admissible under the strict requirements of Article 135 of the Civil Code.
- If such evidence should be limited solely to establishing the continuous possession of the status of a natural child or if it may also serve to conclusively prove paternity.
- Scope of Judicial Inquiry
- Whether the judge may be influenced by evidence that proves the defendant was in fact the father, even when such evidence is not of itself sufficient to establish the necessary elements of a written recognition or continuous possession as mandated by law.
- Whether permitting such evidence would effectively transform the nature of the proof required from one strictly defined by the Civil Code to one that embraces a broader inquiry into the facts of parentage.
- Impact on Judicial Determination
- Whether the improper admission of the evidence in question prejudiced the lower court’s decision by leading it to base its ruling on facts beyond those expressly authorized by statutory law.
- The question of whether a reversal of the lower court’s decision is warranted on the ground that evidence not conforming to the legislative scheme was improperly received.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)