Case Digest (G.R. No. 39537)
Facts:
Irene Reyes (alias Irene Ramero, alias Irene Delgado), Moises Villanueva and Genoveva Ramero v. Court of Appeals, Placida Delgado, Domingo Delgado, Paula Delgado and Maxima Delgado, G.R. No. L-39537. March 19, 1985, the Supreme Court Second Division, Makasiar, J., writing for the Court.
On January 29, 1967, respondents Placida Delgado, Domingo Delgado, Paula Delgado and Maxima Delgado (plaintiffs below) filed a complaint in the Court of First Instance (CFI) of Batangas (Civil Case No. 1144) seeking reconveyance: they alleged that petitioner Irene Delgado had fraudulently executed an extrajudicial self-adjudication (Exh. 24) causing cancellation of several Transfer Certificates of Title (TCTs) and issuance of new titles in Irene’s name over parcels in Quezon and Batangas. Plaintiffs asserted that they, as siblings and heirs of the deceased Francisco Delgado, were entitled to those properties and that Irene had engaged in fraud and abuse of confidence.
Irene (defendant below and petitioner here) answered on March 2, 1967, claiming she was the illegitimate (spurious) daughter of Francisco Delgado and his common-law partner Genoveva Ramero, had been reared and supported by them, and thus was entitled to inherit; she also filed a counterclaim asserting rights in the estate of Francisco’s mother. Pretrial was conducted August 15, 1967. Plaintiffs later moved (March 25, 1969) to admit an amended answer to Irene’s counterclaim; the lower court admitted it April 14, 1969.
After trial, the CFI rendered judgment on December 26, 1969 dismissing the reconveyance action and declaring Irene lawful owner of the eight parcels; it dismissed Irene’s counterclaim for insufficiency of evidence. Both sides appealed to the Court of Appeals (CA).
The CA Special Division of Five reversed on October 7, 1974, declaring Irene’s deed of self-adjudication null and void, cancelling the TCTs issued in her name and reinstating the original titles in the name of Francisco Delgado; it held that although Irene was a spurious daughter, she could not inherit because she had not been recognized voluntarily or judicially. The CA affirmed that alleged loan claims were without merit and declined to adjudicate Irene’s counterclaim in light of its finding that she was not an heir.
Petitioners filed a petition for certiorari to the Supreme Court (petition filed December 2, 1974). The Court initially denied the petition for review in a January 15, 1975 resolution; petitioners moved for reconsideration (filed Februa...(Pro-only)
Issues:
- Must an illegitimate child other than natural (a spurious child) be voluntarily recognized or judicially acknowledged before he or she may inherit from the alleged parent?
- Was there sufficient legal recognition of petitioner Irene Delgado by Francisco Delgado to entitle her...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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