G.R. No. 39537 - Reyes vs. Court of Appeals

On January 29, 1967, the private respondents (plaintiffs) filed a complaint in the Court of First Instance of Batangas, Branch I, seeking a reconveyance of several parcels of land located in Tayabas, Quezon (four parcels) and Pagbilao, Quezon (one parcel) in favor of Placida Delgado, Domingo Delgado, and Paula Delgado, and an additional reconveyance of three parcels in Alitagtag, Batangas in favor of Maximina Delgado.
The complaint alleged that the defendant, Irene Reyes (also known as Irene Ramero or Irene Delgado), through acts of fraud, misrepresentation, abuse of confidence, and falsification, had executed a self-adjudication deed (documented as Exhibit “24”) resulting in the cancellation of several Transfer Certificates of Title and the issuance of new ones in her name. Additionally, it was alleged that a common fund loan of ₱23,000.00 was borrowed by Irene and her spouse Moises Villanueva, which the plaintiffs claimed had been misappropriated.

On or about March 2, 1967, defendant Irene Delgado answered the complaint, asserting that she was the illegitimate daughter of Genoveva Ramero and the deceased Francisco Delgado.
In her answer, Irene set up an affirmative defense claiming that despite her illegitimacy, she had been reared as Francisco Delgado’s daughter, having been acknowledged and supported by him throughout her education and life.
Furthermore, Irene filed a counterclaim, asserting her right to represent her late father and claim a share in the inheritance of Francisco Delgado, as well as seeking acknowledgment of her indigeneity as his child.

On March 16, 1967, the plaintiffs submitted an answer to Irene’s counterclaim, denying her filiation claim and arguing that the properties in question had already been disposed of during the lifetime of Francisco Delgado’s mother.
A pre-trial was held on August 15, 1967, in Civil Case No. 1144, followed by a trial on the merits.
On December 26, 1969, the Court of First Instance dismissed the action for reconveyance, declaring Irene Delgado as the lawful owner of the eight parcels of land. The counterclaim filed by Irene was also dismissed for insufficiency of evidence.

Both parties appealed: the plaintiffs on the basis of their reconveyance complaint and the defendant on her counterclaim.
The Court of Appeals, sitting as a Special Division of Five, rendered its decision on October 7, 1974.

The CA reversed the lower court’s decision by declaring the self-adjudication deed executed by Irene Delgado null and void.
The transfer certificates issued in Irene’s name were cancelled and reinstated in the name of Francisco Delgado.
The extrajudicial declaration concerning the three parcels in Alitagtag, Batangas, was likewise nullified.
Regarding the claim on a ₱23,000.00 common fund loan and Irene’s counterclaim on successional rights, the CA affirmed that the evidence was insufficient, particularly noting that although she was the spurious daughter of Francisco Delgado, she was not duly recognized either voluntarily or by court action.

On December 2, 1974, petitioners (Irene and her spouse) filed a petition for certiorari to review the CA decision.
A resolution denying the petition was rendered on January 15, 1975, based on lack of merit, followed by a motion for reconsideration by the petitioners and subsequent comments and replies exchanged by the parties.
Ultimately, the Supreme Court reaffirmed the ruling of the Court of Appeals, dismissing the petition, and upheld that Irene Delgado had not met the legal requirements for recognition as an heir.

Irene proffered several documents to substantiate her claim of filiation, including:

Her record of birth (with multiple exhibits showing variations in the name and details of the alleged father).
A baptismal certificate listing Francisco Delgado as her father.
A secondary student permanent record and a written consent allegedly given by Irene to the operation of her alleged father.
A marriage contract that mentioned Francisco Delgado’s consent to her marriage.
Family pictures purportedly showing a relationship with Francisco Delgado.

The Court found that none of these documents satisfied the proper legal form required for recognition. In particular, the records lacked authenticity and the mandatory signatures by Francisco Delgado or compliance with the requisites of public instruments as prescribed by law.

The Sufficiency of Recognition Required for Illegitimate (Spurious) Children

Whether the evidence presented by Irene Delgado met the mandatory requirements under the Civil Code for acknowledgment or recognition of an illegitimate child (specifically those not classified as natural by law).

Whether the deed of self-adjudication executed by Irene Delgado, based on her unrecognized filiation, is legally valid.
Whether the cancellation and reinstatement of Transfer Certificates of Title in the name of Francisco Delgado were proper remedies to set aside Irene’s self-adjudication.

Whether Irene Delgado, without voluntary or judicial recognition, can assert her rights to inherit from Francisco Delgado’s estate.
Whether the secondary evidences (e.g., birth and baptismal certificates, school records, and marriage contract) suffice to prove her filiation for successional purposes.