Facts:

• The case concerns the testate estate of Juan Jose Vidaurrazaga, who was killed in February 1945 during the liberation of Manila.
• A document dated May 5, 1931, claiming to be his last will and testament was submitted for probate in the Court of First Instance of Manila, recorded as Civil Case No. 70186.
• On June 23, 1945, Teopista Vidaurrazaga, the petitioner, entered her appearance in the probate case.
• On March 21, 1946, she filed a motion asserting her status as an acknowledged natural child of the deceased and requested to be declared an heir entitled to a share of his estate.
• Teopista claimed to have been born on December 6, 1912, in Kabankalan, Negros Occidental, to Balbina Iligan and Juan Jose Vidaurrazaga.
• The estate administrator, Francisco Ruiz, opposed her motion, denying her claim of being the natural daughter and asserting that she had not been recognized, thus lacking the right to inherit.
• The trial court denied Teopista's petition, leading her to appeal directly to the Supreme Court.
• On September 8, 1949, the case was certified to the Court of Appeals due to the factual questions it raised.
• The Court of Appeals upheld the trial court's decision, prompting Teopista to seek a review from the Supreme Court via certiorari.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the decision of the Court of Appeals.
• Teopista Vidaurrazaga was not recognized as a natural child of Juan Jose Vidaurrazaga and was thus not entitled to inherit from his estate....(Unlock)

Ratio:

• The Court reasoned that acknowledgment of a natural child under Article 131 of the old Civil Code requires clear and formal recognition, which Teopista failed to provide.
• The evidence she submitted, including a birth certificate and testimonies, did not meet the legal standards for acknowledgment.
• The birth certificate was inadequate as it was not signed or sworn to by both parents, as requ...continue reading