Case Digest (G.R. No. 230049) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Bernie Santiago v. Rommel C. Jornacion and the City Civil Registrar of Marikina City (G.R. No. 230049, October 6, 2021), petitioner Bernie Santiago sought to establish his paternity of Maria Sofia Gabutin Jornacion (born March 24, 2001) and to correct entries in her birth certificate. On May 17, 2013, he filed before the Regional Trial Court (RTC) of Marikina City a petition under Rule 108, impleading Sofia, her recorded father Rommel C. Jornacion, her half-siblings Kevin and Samantha Jornacion, and Bernie’s own siblings. Bernie alleged that Sofia was the fruit of his relationship with Magdalena O. Gabutin, who was legally married but effectively separated from Rommel, and that Sofia’s birth registration erroneously named Rommel as father. He sought to change Sofia’s surname to Santiago, identify himself as her biological parent, and correct parental details. Bernie presented evidence including Sofia’s birth certificate, marriage and death certificates of the parties, photogr Case Digest (G.R. No. 230049) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition and Amended Petition
- On May 17, 2013, petitioner Bernie Santiago filed with the RTC of Marikina City a petition to establish his paternity over Maria Sofia Jornacion (Sofia) and to have the City Civil Registrar correct entries in Sofia’s Birth Certificate.
- Through a Motion for Leave and an Amended Petition, he impleaded as parties Sofia; her recorded father, Rommel C. Jornacion; her half-siblings Kevin and Samantha; and Bernie’s own siblings, seeking changes to Sofia’s surname, father’s name, citizenship, age, marital status of parents, and informant status.
- Allegations and Supporting Evidence
- Bernie alleged that Sofia was born on March 24, 2001 from his relationship with Magdalena O. Gabutin, who was then separated but still legally married to Rommel. To avoid scandal, Rommel was registered as Sofia’s father. Bernie claimed he supported Sofia financially since birth.
- He submitted various documents: death certificates, marriage and annulment contracts of Rommel and Magdalena, Sofia’s Birth Certificate, photographs, money-transfer receipts, DNA test results from a U.S. laboratory (DDC) via a Philippine partner, passports, and affidavits.
- Procedural History
- RTC Order (Nov. 12, 2013): Dismissed the petition for lack of standing, viewing it as a collateral attack on Sofia’s legitimacy, and found the motion to file the Amended Petition moot.
- RTC Reconsideration Denied (Feb. 12, 2014): RTC affirmed dismissal.
- Court of Appeals Decision (May 23, 2016): Affirmed RTC, allowed OSG’s late comment in interest of justice, held Bernie was not a proper party and that only Rommel or his heirs could directly impugn legitimacy under the Family Code.
- CA Resolution (Feb. 6, 2017): Denied reconsideration.
- Supreme Court: Bernie filed this petition for review under Rule 45.
Issues:
- Did the RTC and CA err in dismissing Bernie’s Rule 108 petition for lack of legal standing and in considering the OSG’s late Comment/Opposition?
- Can a petition under Rule 108 of the Rules of Court be used to establish or impugn filiation (including status changes) despite the presumption of legitimacy under the Family Code?
- Must a third party (non-spouse, non-heir) be barred from filing filiation or correction proceedings when scientific evidence rebuts the presumption of legitimacy?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)