G.R. No. 234681 - Salvador vs. Salvador

Procedural Background
On November 29, 1976, petitioner William Liyao, Jr., represented by his mother Corazon G. Garcia, filed Civil Case No. 24943 before the RTC of Pasig, Branch 167, to compel respondents Juanita Tanhoti‐Liyao, Pearl Margaret L. Tan, Tita Rose L. Tan and Linda Christina Liyao to recognize him as the illegitimate son of the late William Liyao.
The complaint was amended to allege continuous possession and enjoyment of the status of William Liyao’s child and prior acknowledgment by the decedent.

Corazon was legally married to Ramon M. Yulo but had lived separately from him for over ten years when she began cohabiting with William Liyao (1965–1975).
They lived with Corazon’s two children from her marriage to Yulo; the arrangement was known to Liyao’s legitimate daughters, who worked in the couple’s company, Far East Realty Investment, Inc.

William Liyao, Jr. was born June 9, 1975. The decedent visited mother and child in the hospital, paid all expenses, had his secretary secure the birth certificate, and opened a bank account for the newborn.
Liyao publicly introduced the child as his son, had vacation and social‐event photos taken with him, acknowledged paternity at his last birthday party (November 22, 1975), and planned an elaborate baptism.

Witness Testimonies for Petitioner
Maurita Pasion, Gloria Panopio, and Corazon’s older children Enrique and Bernadette testified to seeing:

the cohabitation at White Plains and Greenhills residences;
Liyao’s material support, photographs with the child and family, and public acknowledgments of paternity.

William Liyao was legally married to Juanita Tanhoti‐Liyao, never separated, resided at San Lorenzo Village, and suffered two strokes in 1974, rendering him bedridden for periods.

Corazon remained married to Ramon Yulo without legal separation; occasional visits by Yulo were observed at Corazon’s workplace and residence.

Ramon Pineda, Liyao’s driver/bodyguard (1962–1974), confirmed Liyao’s health decline, lack of chauffeuring duties for Corazon, and sighting of Yulo at the office garage.

Lower Court Rulings
RTC Decision (August 31, 1993): Declared William Jr. the illegitimate (spurious) son of the deceased, ordered respondents to recognize him as a compulsory heir, and awarded costs.
CA Decision (June 4, 1999): Reversed RTC, holding that the presumption of legitimacy may only be impugned by the husband or his heirs upon proof of physical impossibility of marital access; found petitioner’s evidence insufficient.

Whether a child born during a valid marriage may, through his own action (or that of his mother), impugn his legitimacy to establish filiation with another man and claim succession rights.
Whether petitioner presented clear, competent and positive proof of paternity by the late William Liyao.