G.R. No. 104818 - Domingo vs. Court of Appeals

Petitioner Arturio Trinidad filed a complaint for partition and damages against respondents Felix Trinidad (deceased) and Lourdes Trinidad on August 10, 1978, before the Court of First Instance of Aklan, claiming to be the legitimate son of the late Inocentes Trinidad.
Patricio Trinidad, the original owner of four parcels of land in Barrio Tigayon, Kalibo, Aklan, died in 1940, leaving the properties to his three children: Inocentes, Lourdes, and Felix Trinidad.
Felix Trinidad died without issue on October 28, 1982; no substitution was made.
Petitioner demanded partition of the land into three equal shares, claiming entitlement as a legitimate son of Inocentes Trinidad, but respondents denied the claim.

The trial court ruled in favor of the petitioner on July 4, 1989, acknowledging petitioner as the legitimate son of Inocentes Trinidad and entitled to one-third of the parcels.
Petitioner’s evidence included:

Testimony of Jovita Gerardo, barangay captain and longtime neighbor, who attested to the marriage of Inocentes Trinidad and Felicidad Molato solemnized by a Protestant pastor in 1942, and continuous cohabitation as husband and wife. She also identified family photographs showing the petitioner with respondents and their children.
Testimony of Isabel Meren who corroborated the marriage and family relations.
Petitioner’s own testimony confirming his birth on July 21, 1943, his baptismal certificate listing Inocentes and Felicidad as parents, and his living with the respondents as their nephew for several years.
Presentation of two family photos depicting the petitioner and respondents together with the petitioner’s children.
Certification from the Local Civil Registrar of New Washington, Aklan, that birth, death, and marriage records were destroyed during the Japanese occupation and later.

Testimony of Pedro Briones and Beatriz Trinidad Sayon asserting that Inocentes Trinidad died single and without issue in 1940 or 1941.
Lourdes Trinidad’s denial that Inocentes Trinidad was married or fathered petitioner, and denial that petitioner had ever lived with them.
Lourdes admitted holding petitioner’s daughter in a photo but claimed it was a courtesy, not indicative of family relations. She also explained that her brother Felix died without issue.

Petitioner’s witnesses disputed respondents’ timeline of Inocentes’ death and marital status, affirming the 1942 marriage ceremony and petitioner’s legitimacy.

The Court of Appeals reversed the trial court decision on the ground that petitioner failed to present sufficient proof of his parents’ valid marriage and that acquisitive prescription had run in favor of respondents.
The Court of Appeals denied the petitioner’s motion for reconsideration citing lack of merit and absence of new matters to modify its decision.

Whether petitioner proved by preponderant evidence the existence of a valid marriage between his parents, Inocentes Trinidad and Felicidad Molato.
Whether petitioner sufficiently established that he is the legitimate son of Inocentes Trinidad.
Whether the Family Code’s provisions apply, given the timing of the trial court’s decision.
Whether petitioner’s legitimacy can be collaterally attacked in the partition case.
Whether respondents acquired ownership of the property through acquisitive prescription.