G.R. No. 177775 - People vs. Dizon

The petition for review was filed by Antonio Macadangdang (petitioner) to set aside the decision of the Court of Appeals which had reversed the dismissal rendered by the Court of First Instance of Davao, Branch IX.
The original action for recognition and support was filed by Elizabeth Mejias (respondent) seeking to have minor Rolando declared as the illegitimate child of petitioner and to secure a monthly support payment of P350.00.

In March 1967, Elizabeth Mejias allegedly had illicit intercourse with Antonio Macadangdang.

The encounter is described as the initial “incident” between the petitioner and respondent.
This sexual encounter, marked by nonconsensual overtones in evidentiary testimony, became the basis for the ensuing controversy.

Subsequent to the affair, respondent separated from her husband, Crispin Anahaw, although evidence of a formal or substantiated separation was not convincingly established.
On October 30, 1967, respondent gave birth to a baby boy, later baptized on December 24, 1967.

The birth occurred seven months after the illicit encounter, suggesting that the conception likely took place around January 1967, following a normal nine-month gestation.
Testimonies from respondents and witnesses (including that of the yaya, Patrocinia Avila) emphasized that the child was born full-term and under normal circumstances.

On April 25, 1972, respondent filed a complaint for recognition and support in the Court of First Instance of Davao, which led to pretrial conferences and agreed stipulations between the parties.
The lower court dismissed the complaint on February 27, 1973, basing its reasoning on provisions of the Civil Code and the Rules of Court.
Elizabeth Mejias appealed the dismissal on April 18, 1973, citing alleged errors in the application of Articles 255 and 256 of the Civil Code and certain provisions of Rule 131 of the Revised Rules of Court.
The Court of Appeals reversed the lower court’s decision on June 2, 1978, declaring minor Rolando the illegitimate son of Antonio Macadangdang.
Motions for reconsideration were filed by respondent but were denied on November 6, 1978, leading petitioner to file the present petition for review.

Respondent’s own testimony indicated feelings of worry, shock, and humiliation following the incident and admitted that the encounter led to a separation from her husband along with associated monetary estimations.
The testimonies highlighted that respondent continued to maintain close physical proximity with her husband despite the alleged separation.
Witnesses confirmed that respondent’s activities (such as returning to her parents’ house in Samal, where her husband resided) underscored the possibility of marital access during the conception period.
Documentary evidence, including a Certificate of Baptism, was presented though it did not conclusively prove the paternity claimed by respondent.

Whether minor Rolando is conclusively presumed to be the legitimate child of respondent Elizabeth Mejias and her husband, Crispin Anahaw, under Articles 255 and 256 of the Civil Code and corresponding provisions of Rule 131 of the Revised Rules of Court.
Whether the fact that the child was born seven months after the alleged illicit intercourse invalidates the presumption of legitimacy.

Whether the wife (respondent) may initiate an action to bastardize her child against petitioner without giving the legally presumed father (her husband) an opportunity to be heard.
Whether procedural and substantive requirements regarding the contestation of legitimacy were properly observed in the proceedings.