G.R. No. 85723 - Rodriguez vs. Court of Appeals

On October 15, 1986, an action for compulsory recognition and support was filed before the Regional Trial Court, Branch 9, Baguio-Benguet by respondent Clarito Agbulos against petitioner Bienvenido Rodriguez.
The purpose of the action was to compel recognition of private respondent’s paternity and to secure appropriate support.

During the trial, the plaintiff (Clarito Agbulos) presented his mother, Felicitas Agbulos Haber, as the first witness to establish relevant facts, including the identity of his putative father.
During her direct examination, when asked to identify the alleged father, counsel for the defendant (Rodriguez) raised a timely objection which the trial court sustained, thereby disallowing the testimony that could reveal the identity of the father.

Following the ruling of the trial court, a petition for review on certiorari was filed by the plaintiff before the Supreme Court questioning the order that excluded the testimony of Felicitas Agbulos Haber.
On March 18, 1988, the Supreme Court referred the petition to the Court of Appeals (CA-G.R. SP No. 14276), which subsequently promulgated a Decision on November 2, 1988, addressing the contested testimony.

Not dismissing the petition on the ground that the order of the trial court disallowing the testimony was interlocutory and non-reviewable on its own.
Reversing the trial court’s order and improperly allowing the mother's testimony.

Article 280 of the Civil Code of the Philippines, which prohibits a parent from revealing the name of the other party when a separate and voluntary recognition is made.
Contrastingly, private respondent relied on Article 283 of the Civil Code and Section 30, Rule 130 of the Revised Rules of Court, which he argued allowed his mother’s testimony regarding his paternity.

The decision references Navarro v. Bacalla, clarifying that the earlier ruling allowed the mother’s testimony in a context where no objection was raised and when the paternity issue was settled by the trial court.
The Court analyzed the origins of Article 280, comparing it with Article 132 of the Spanish Civil Code of 1889, and highlighted that its prohibition on revealing the name of the other parent applied only to a voluntary recognition rather than to cases of compulsory recognition.
Commentaries by Senator Arturo M. Tolentino and Justice Eduardo Caguioa were noted, both supporting the view that the prohibition relates solely to the act of voluntary recognition.

The evolution from the Civil Code to the Family Code was discussed, noting that the provisions similar to those in Articles 276-280 of the Civil Code were repealed.
The Family Code now permits the establishment of illegitimate filiation on the same evidentiary basis as legitimate filiation, particularly under Article 172 which echoes the provisions of Article 283 on the admissibility of evidence.

Whether the petition for review on certiorari could be deemed proper given that the order of the trial court disallowing the testimony was interlocutory and not separately reviewable.
Whether the exception to the general rule on reviewability (i.e., to prevent irreparable damages or failure of justice) justified the intervention of the appellate court in this instance.

Whether the testimony of Felicitas Agbulos Haber regarding the identification of the putative father should be admitted despite the prohibition contained in Article 280 of the Civil Code.
Whether the prohibition in Article 280 applies to an action for compulsory recognition, particularly when set against the allowances provided by Article 283 and relevant evidentiary rules.

The extent to which Article 280’s ban on disclosing the identity of the other parent is applicable in situations where the recognition is compelled by the court rather than voluntarily made.
How the legislative intent behind the prohibition in the Civil Code, as contrasted with the liberalization embodied in the Family Code provisions, affects the admissibility of evidence in filiation cases.