G.R. No. 200344 - Miller vs. Miller y Espenida

John Miller (John) and Beatriz Marcaida were legally married and had four children: Glenn M. Miller (Glenn), Charles Miller, Betty Miller, and John Miller, Jr.
John died, after which Joan Miller (also referred to as Joan Miller y Espenida or Johnlyn Miller y Espenida), allegedly his illegitimate child with Lennie Espenida (Lennie), asserted her claim.

Joan, through Lennie, filed a Petition for Partition and Accounting of John’s estate, presenting her Certificate of Live Birth reflecting John as her father.
Glenn filed a separate Petition to cancel Joan’s Certificate of Live Birth, seeking to remove John’s surname “Miller” from Joan’s birth certificate, claiming no acknowledgment by John of Joan as his child.
Glenn alleged John did not sign Joan’s birth certificate, and there was no proof John consented to his name in her birth records.

Joan maintained that John had an amorous relationship with Lennie from 1978 until his death in 1990, and Joan was born of that relationship on June 25, 1982.
Joan admitted John did not sign her birth certificate but claimed he continuously recognized her as his child during his lifetime.
Evidence presented included:

Joan’s upbringing in John’s ranch and education financed by John.
John’s July 5, 1984 letter mentioning Joan to Lennie.
John’s holographic will which bequeathed Joan a 1/8 share of his estate.
February 14, 1987 document appointing Betty as Joan’s guardian and inheritance administrator.
Educational plan arranged for Joan by Betty under John’s instructions.

Joan alleged Glenn’s petition was a harassment tactic, seeking damages as counterclaim.

Glenn argued the authenticity of John’s documents (letters and holographic will) was unproven, failing to establish filiation.
Evidence showed Joan had two birth certificates (Local Civil Registrar Nos. 760 and 825) with John’s name as father, but neither had John’s signature or acknowledgment.
Glenn discovered Joan living at their ranch and her multiple birth certificates post John’s death and sought to remove the Miller surname.
Joan and Lennie testified to John’s acknowledgment evidenced by documents and John’s consistent recognition of Joan as his daughter.

The RTC ruled in favor of Joan, recognizing acknowledgment by John through authentic writings and actions, including the will and letters.
The RTC dismissed Glenn’s petition to cancel the birth certificate and ordered Joan to continue using the surname Miller.
Glenn appealed, which the Court of Appeals (CA) denied, citing the holographic will as sufficient evidence of paternity and recognition by John under Articles 172 and 173 of the Family Code.
The CA ruled that Joan need not prove the authenticity of the documents; the burden lies on Glenn who failed to establish forgery or invalidity.
After denial of motion for reconsideration by the CA, Glenn’s surviving legal heirs filed a Petition for Review on Certiorari before the Supreme Court.

Petitioners argued that since Joan was born in 1982, Article 368 of the Civil Code applies, mandating illegitimate children bear their mother’s surname.
Article 176 of the Family Code, which allows illegitimate children to use the father’s surname, should not apply retroactively.
Petitioners claimed the will did not satisfy the requirements for a private handwritten instrument and questioned the validity of acknowledgment.
Petitioners asserted that Joan’s mother, Lennie, was convicted of falsification of a public document involving one of Joan’s birth certificates, casting doubt on the authenticity of all certificates.
The petitioners contended that acknowledgment by the father must precede surname use and suggested DNA evidence should have been presented.
A formal administrative complaint was lodged against the RTC judge for alleged conflict of interest.

Joan maintained sufficient proof of acknowledgment through the will, letters, and designation of guardian.
She invoked Republic Act No. 9255 allowing illegitimate children to use the father’s surname regardless of birthdate.
Joan challenged petitioners’ claims of forgery and maintained the documents’ authenticity.

The petition was a Petition for Correction of Entries in the Certificate of Live Birth governed by Rule 108 of the Rules of Court.
Rule 108 provides for correction or cancellation of civil registry entries limited to innocuous or clerical errors that are non-controversial and supported by indubitable evidence.
The Court noted that changing Joan’s surname affects her filiation and status, constituting a substantial change, not a mere clerical correction.
Citing precedent, the Court emphasized legitimacy and filiation issues must be raised in direct actions, not collaterally by petition for correction of birth records.

Whether the Court of Appeals erred in affirming the Regional Trial Court judgment allowing Joan Miller y Espenida to continue using the surname "Miller" in her Certificate of Live Birth.

Whether a Petition for Correction of Entries in the Civil Registry under Rule 108 of the Rules of Court is the proper mode to question legitimacy and filiation.

Whether the acknowledgment of illegitimate filiation through a holographic will and other writings is sufficient to allow the use of the father’s surname.

Whether the provisions of the Family Code allowing illegitimate children to use the father’s surname apply retroactively in this case.

Whether the alleged falsification of one birth certificate undermines the authenticity of documents relied upon by Joan.