Facts:

This case involves Julio Pareja, Regina Pareja, Jose Pareja, and Soledad Pareja Marcial as petitioners and appellants against Paz Pareja and others as respondents and appellees. The case was decided on April 16, 1958, in the Supreme Court of the Philippines. The background stems from a previous ruling in G. R. No. L-5824, where the petitioners sought to be declared as acknowledged natural children of the deceased Natividad Pareja, who died during World War II. The basis for their claim was an official document known as "Information for Membership Insurance," signed by the intestate on March 12, 1939, which listed them as beneficiaries. This document was deemed an "indubitable document" under the Spanish Civil Code, allowing recognition even after the death of the father, as long as the claim was made within six months of its discovery. The order from that case was reversed, granting the petitioners the opportunity to secure a declaration of recognition as nat

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Facts:

Background of the Case

• The case involves a petition for the recognition of natural children of the late Natividad Pareja based on an official document known as "Information for Membership Insurance."
• The petitioners (Julio Pareja, Regina Pareja, and Jose Pareja) sought a declaration that they were acknowledged natural children of the intestate, while the respondents (including Paz Pareja) contested this acknowledgment.

The Indubitable Document (Exhibit A)

• Exhibit A is an official insurance membership document dated March 12, 1939, signed by the Intestate in his capacity as an employee insured under the Government Service Insurance System.
• The document explicitly designates the following as beneficiaries:
• "Julio Pareja – Son"
• "Regina Pareja – Daughter"
• "Jose Pareja – Son"
• "Paz Pareja – Daughter"
• This document is identified as an indubitable document under Article 135, paragraph 1 of the Spanish Civil Code.

Legal Framework and Prior Jurisprudence

• Under Article 137, paragraph 2 of the Spanish Civil Code, recognition based on an indubitable document may be made even after the death of the parent if the document, previously unknown, is discovered and the acknowledgment action is instituted within six months from such discovery.
• The case references a prior decision (G. R. No. L-5824, promulgated May 31, 1954) which elaborated on this principle and the conditions required for recognition as natural children.

Timeline and Procedural History

• The deceased died during the war, and an application for administration was later filed by Paz Pareja on May 21, 1945, with no allegation made that the children were recognized as natural.
• Exhibit A appears to have been secured from the Government Service Insurance System on December 10, 1949.
• Petitioners allege that they only came to know of the existence of the insurance application (and thus the potential for recognition) in November 1949, after the Intestate’s death.
• The oppositors, however, contend that petitioners had prior knowledge of the insurance membership application and that no action was taken within the stipulated period, noting that over 10 years had elapsed between the presentation of the insurance document and the filing of the action.

Evidence and Findings at Trial

• The trial court found that the petitioners did not introduce evidence to establish that they were unaware of Exhibit A for a period of more than six months before December 2, 1949.
• The court recognized the significance of Exhibit A but held that the requisite condition for timely acknowledgment under Article 137, paragraph 2 was not met.

Issue:

Timeliness of the Acknowledgment Action

• Whether the petitioners commenced the acknowledgment action within the six-month period following the discovery of the indubitable document.
• Whether the alleged late discovery (in November 1949) is sufficient to override the elapsed time since the document’s existence.

Status and Nature of Exhibit A

• Whether Exhibit A qualifies as an indubitable document under Article 135, paragraph 1 of the Spanish Civil Code.
• Whether Exhibit A should be treated as a public document as described in Article 131 of the Civil Code, which may affect the basis for an action for recognition.

Evidentiary Basis for Recognition

• Whether the petitioners have established, through documentary evidence, that they were unaware of the insurance membership document for a period that satisfies the six-month requirement for invoking Article 137, paragraph 2.
• Whether the failure to act during the lifetime of the Intestate carries sufficient weight to bar the petitioners' claim for acknowledgment as natural children.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)