G.R. No. L-11483-11484 - In the matter of the testate estate of the deceased Edward E. Christensen, Adolfo Cruz Aznar vs. Maria Helen Christensen Garcia and Bernarda Campore-Dondo

Edward E. Christensen, an American citizen, resided in Davao in 1913 and became manager of Mindanao Estates in Padada in 1914.
A group of laborers from Argao, Cebu, arrived about 1917, including Bernarda Camporedondo, who became assistant to the cook.
Bernarda Camporedondo and Edward E. Christensen began living together as husband and wife; the lower court found the relationship continuous for over thirty years until Edward E. Christensen died on April 30, 1953.
Two children allegedly resulted from the relationship: Maria Lucy Christensen Daney (born April 25, 1922) and Maria Helen Christensen Garcia (born July 2, 1934).

The decedent executed a will naming Adolfo Cruz Aznar as executor; the will was presented for probate in Special Proceedings No. 622, Court of First Instance of Davao.
The will declared that the decedent had but one child, MARIA LUCY CHRISTENSEN (now Mrs. Bernard Daney), and no other descendants (Pars. 3 and 4, Exh. A).
The will bequeathed P3,600 to MARIA HELEN CHRISTENSEN, to be held in trust at the Davao Branch of the Philippine National Bank and paid at P100 monthly (Par. 7, Exh. A).
The will bequeathed P1,000 to BERNARDA CAMPOREDONDO (Par. 8, Exh. A).
The will gave all remainder and residue as a life income to MARIA LUCY CHRISTENSEN DANEY, with contingent remainders to the decedent's sister and nieces/nephews if Lucy died without issue (Par. 12, Exh. A).
The will nominated Adolfo Cruz Aznar as executor (Par. 13, Exh. A).

Maria Helen Christensen Garcia and Bernarda Camporedondo separately opposed probate.
Maria Helen Christensen Garcia contended the will lacked legal formalities, that testamentary dispositions were illegal because both she and Lucy were children of the decedent yet received unequal shares, and that Adolfo Cruz Aznar had adverse interests.
Bernarda Camporedondo claimed ownership of one-half of the estate as co-owner by virtue of long cohabitation with the decedent and alleged acquisition of property by their common efforts.
The probate court dismissed Bernarda Camporedondo's opposition for lack of succession rights in that proceeding and required her to file a separate action; she instituted Civil Case No. 1076, Court of First Instance of Davao.
Adolfo Cruz Aznar was appointed special administrator on May 21, 1953, after filing a P5,000 bond; letters of special administration were issued.

Maria Helen Christensen Garcia filed a supplemental opposition and sought judicial acknowledgment as an acknowledged natural child, alleging continuous possession of the status of decedent's natural child and offering evidence of paternity.
Adolfo Cruz Aznar and Maria Lucy Christensen Daney opposed, asserting the mother had relations with other men and that the decedent had disavowed paternity and that Helen used the surname illegally.
Oppositor produced testimony from community members, teachers, family portraits, greeting cards, and letters to prove recognition by the decedent and treatment as a family member.
Appellants introduced testimony and an affidavit by Zosimo Silva to show the mother had an affair around the time of Helen’s conception; appellants also relied on purported repudiations by the decedent.
The trial court found that Maria Helen Christensen Garcia had been in continuous possession of the status of a natural child and directed Maria Lucy Christensen Daney to acknowl...(Subscriber-Only)

Whether the lower court erred in finding that Maria Helen Christensen Garcia had been in continuous possession of the status of a natural child of Edward E. Christensen.
Whether the lower court erred in directing Maria Lucy Christensen Daney to acknowledge Maria Helen Christensen Garcia as a natural child of the decedent.
Whether Bernarda Camporedondo was entitled to one-half of the decedent's properties as co-owner by virtue of living with the decedent as husband and wife.
Whether Republic Act No. 386 (Civil Code of the Philippines) or Article 144 (quoted in the decision as Art. 114) applied retroactively to subject properties acqu...(Subscriber-Only)