Case Digest (G.R. No. 84647)
Facts:
Maria Alicia Leuterio v. Court of Appeals and Heirs of Benito Leuterio, G.R. No. 84647, May 23, 1991, Supreme Court First Division, Narvasa, J., writing for the Court.
Petitioner Maria Alicia Leuterio claimed she was the natural daughter of Pablo Leuterio and Ana Maglanque, conceived when the parents were free to marry, and that she was entitled to compulsory recognition and subsequent legitimation by virtue of acts and writings she presented after Pablo's death. Pablo died on June 15, 1950, leaving an estate in Pampanga; he married Ana Maglanque on February 25, 1950, months before his death. Ana took possession and administered the estate after his death.
In 1957 Patrocinio Apostol, a niece of Pablo, filed for appointment as guardian of Maria Alicia, then 16. Later that year, Benito Leuterio, Pablo's full-blood brother, commenced intestate estate settlement proceedings (Sp. Proc. No. 1316) and sought appointment as administrator; Benito alleged Pablo died a widower and denied any legitimate child. Ana and Maria Alicia (through Patrocinio) opposed Benito's petition, and the Probate Court appointed Ana administratrix.
On October 19, 1962, Maria Alicia filed an "Assertion of Rights" in the settlement proceedings, claiming to be Pablo's only forced heir, and on December 4, 1962, she filed an "Amended Petition for Confirmation of Acknowledgment and Legitimation," asserting continuous possession of the status of Pablo's natural child and producing documentary and testimonial evidence, including a civil registry birth certificate (Exhibit D), baptismal certificate, photographs, and testimonies she said were "indubitable writings" evidencing Pablo's acknowledgment.
The parties stipulated certain facts and narrowed the contested issues to (1) whether Vicente Leuterio was a legitimate child of Gregoria (later withdrawn), and (2) whether Maria Alicia was the legitimated daughter of Pablo and Ana. Trial chiefly concerned the second issue. After trial the Probate Court, by order dated March 10, 1971 (Judge Andres C. Aguilar), dismissed Maria Alicia's petition for lack of merit, finding her documentary and testimonial proofs insufficient, some documents spurious, and concluding Pablo had desisted from acknowledging Maria Alicia.
Maria Alicia appealed to the Court of Appeals. In a Decision promulgated November 12, 1986 (Sixth Division, Luciano, J., with Grino‑Aquino and Cui, JJ., concurring), the Court of Appeals affirmed the Probate Court, rejecting Exhibit D and other proofs as insufficient to establish ...(Pro-only)
Issues:
- Are the Court of Appeals' factual findings, which mirror the Probate Court's findings, subject to review by the Supreme Court in this petition for review on certiorari?
- Did petitioner prove compulsory (involuntary) recognition by Pablo Leuterio such that she was legitimated and entitled to inheritance?
- Does Article 283 of the Civil Code (1950) operate retroactively to aid petitioner's...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)