G.R. No. 204738 - Rodriguez-Angat vs. Government Service Insurance System

Petitioner, Corito Ocampo Tayag, filed a petition for certiorari and prohibition seeking to annul an interlocutory order of the Court of Appeals which denied her motion for reconsideration.
The petition challenges the denial of the motion to dismiss in Civil Case No. 7938, where petitioner was the administratrix of the late Atty. Ricardo Ocampo’s estate.

Private respondent, Emilie Dayrit Cuyugan, in her capacity as mother and legal guardian, filed a “Claim for Inheritance” on April 9, 1987.
The complaint alleged that:

The minor child, Chad D. Cuyugan, is an illegitimate child of the deceased Atty. Ricardo Ocampo, having been born from an illicit amorous relationship between respondent and the deceased.
The deceased possessed real and personal properties in various locations valued at several million pesos.
The estate had not yet been inventoried or distributed among the surviving heirs, which include petitioner's other siblings and minor Chad.

Petitioner filed an answer with counterclaim, contesting the material allegations and asserting multiple affirmative defenses, such as:

The trial court, after a preliminary hearing held on October 20, 1987, denied the motion to dismiss, citing the need for further evidence and scheduling the case for pre-trial.
Following petitioner’s motion for reconsideration (denied on November 19, 1987), she filed a petition for certiorari and prohibition on December 10, 1987.
A subsequent decision by the Court of Appeals, promulgated on May 10, 1990, dismissed petitioner’s petition on the ground that the interlocutory order denying dismissal was not appealable via the special civil action of certiorari.

The appellate court disregarded established exceptions which allow interlocutory orders to be elevated.
Certain substantive issues, particularly those involving the recognition of filiation and interpretation of relevant provisions under the Civil Code and Family Code, were not resolved.
The interlocutory order had grave abuse of discretion amounting to lack or excess of jurisdiction.

Petitioner further argued that the “Claim for Inheritance” filed on behalf of minor Chad was premature since recognition of his filiation by the alleged putative father had not been judicially or voluntarily established.

The case drew comparisons with Paulino vs. Paulino where the necessity of proving acknowledgment by the putative father was underscored.
Prior decisions, including Briz vs. Briz, were cited regarding the joinder of causes of action (compelling recognition and claiming inheritance) in a single complaint.
The conflicting provisions of Article 285 of the Civil Code and Article 175 of the Family Code regarding the prescriptive period for recognition of natural children were thoroughly discussed.
Ultimately, the ruling emphasized that the filing of the complaint under the Civil Code vested the right to the claim, protecting it from adverse effects brought on by later statutory changes.

Whether an interlocutory order (denying the motion to dismiss) may be elevated by way of a petition for certiorari and prohibition.
Whether the “Claim for Inheritance” involving the minor child, Chad D. Cuyugan, is premature given the lack of alleged recognition of filiation by the putative father.

Whether Article 285 of the Civil Code or Article 175 of the Family Code governs the prescriptive period in actions for recognition of natural children.
Whether the right of action of the minor had already vested upon the filing of the complaint under the regime of the Civil Code despite subsequent enactment of the Family Code.

Whether the appropriate remedy for petitioner to challenge the interlocutory order was by an ordinary appeal rather than the special civil action of certiorari and prohibition.
The necessity and validity of joining a cause of action to compel recognition with an inheritance claim.