G.R. No. 234681 - Salvador vs. Salvador

Petitioners are Juanito Anro Salvador, Ken Russel Salvador, and Michael Salvador.
Respondents are Maria Minda A. Salvador (representing herself and the minors Alexis, Jeffrey, Anthony Salvador, and Hyacinth Salvador Yee).
The dispute concerns co-ownership over properties inherited by Juanito from Anatolio Salvador and Rosario Canoy Salvador.
Maria asserts Franklin Salvador, her late husband, was the legitimate son of Anatolio and Rosario, challenging Juanito's sole ownership claim.

It is undisputed Rosario is Franklin’s mother.
Juanito claims Franklin's father was Celedonio Salvador, Rosario's second husband; Franklin was born after Anatolio died.
Juanito claims Anatolio died in 1942; Maria claims April 4, 1944.
Maria states Franklin was born on September 30, 1944, after Anatolio's death but before Rosario's remarriage.
Juanito contends Franklin was a product of Rosario's cohabitation with Celedonio before Anatolio’s death.

In 1976, Juanito emigrated to the US and Rosario acted as administrator of his inherited properties.
Franklin registered his birth in 1993, signing as informant; the birth certificate did not bear Rosario’s signature.
Franklin died in 2000, survived by wife Maria and children.
In 2001, Maria discovered Franklin had disposed of some properties; complaints for estafa filed by Maria against Juanito were dismissed.

In 2005, Maria and her children, including Franklin's other daughter Hyacinth, filed a complaint against Juanito and Franklin's sons from his first wife, for nullity of documents, reconveyance, partition, and damages.
The RTC found Franklin was legitimate son of Anatolio, relying heavily on the 1993 birth certificate and corroborating evidence including a 1947 Philippine Legion letter and death record from family bible showing Anatolio died in 1944.
The RTC declared documents alienating properties null, ordered reconveyance, and accounting of proceeds but denied damages for lack of proof.
The CA affirmed the RTC's decision, emphasizing the prima facie evidentiary value of the birth certificate, including delayed registration, and supporting documentary evidence.

Petitioners argue the birth certificate's delayed registration and absence of Rosario's attestation cast doubt on Franklin's filiation.
Petitioners argue the complaint was untimely for questioning legitimacy and that at most Maria et al. are entitled to one-half of the estate.
Supreme Court affirms the lower courts but modifies ruling ordering partition before reconveyance, remanding to RTC for impleading indispensable parties and conducting partition.

Whether the Court of Appeals erred in affirming the RTC's finding of Franklin Salvador's legitimacy as son of Anatolio and Rosario.

Whether the delayed registration of Franklin's birth certificate could provide prima facie proof of filiation.

Whether the RTC correctly ordered reconveyance of the properties without partition.

Whether Maria and Franklin's heirs are entitled to the full or only a half share of Anatolio's estate.