G.R. No. 205241 - Vizcarra vs. Vizcarra-Nocillado

Petition for Review on Certiorari filed by petitioners—Concepcion A. Vizcarra, Feliciano A. Vizcarra (married to Maria Luisa A. Vizcarra), Victor A. Vizcarra, Evarista A. Vizcarra, and Dionisio A. Vizcarra—challenging prior rulings.
The petition assails the Decision and Resolution of the Court of Appeals (CA) which had affirmed the Regional Trial Court’s (RTC) ruling regarding an Extra Judicial Settlement of the Estate of Ireneo Vizcarra, Constancio F. Vizcarra, and Purificacion F. Vizcarra.

Ireneo Vizcarra was the registered owner in fee simple of two parcels of land in ParaAaque City, covered by Transfer Certificate of Title (TCT) No. 63087.
Ireneo died on September 5, 1993, and was survived by his children, Constancio and Purificacion.
Constancio died on August 18, 2004, leaving behind his wife, Concepcion, and their children (Feliciano, Victor, Evarista, and Dionisio).
Purificacion died on November 19, 2006, without any legitimate issues.
On December 31, 2006, the heirs of Constancio executed an Extra Judicial Settlement of the Estate, which resulted in the cancellation of TCT No. 63087 and subsequent partitioning of the property.
New titles were issued to the heirs of Constancio on January 20, 2007.

On October 4, 2007, respondents filed a complaint before the RTC of ParaAaque City, praying for the nullification of the Extrajudicial Settlement and the cancellation of the new certificates of title.
Respondents claimed that they are the heirs of Silvestre Vizcarra—allegedly born to Ireneo Vizcarra and a woman named Rosalia Ferrer—by representing their deceased father, Silvestre, who predeceased Ireneo.
To prove filiation, respondents presented several key documents:

An NSO Certificate (dated September 11, 2007) indicating that Ireneo was the father of Silvestre.
A 1978 Certification from the Office of the Local Civil Registrar of ParaAaque confirming Silvestre’s birth details.
The marriage contract of Silvestre and Trinidad Agner which mentioned Ireneo as Silvestre’s father.

The RTC ruled in favor of the respondents, declared the Extra Judicial Settlement null and void, ordered cancellation of the new TCT, and directed reconveyance of the property.
The Court of Appeals affirmed the RTC ruling by relying in large part on the validity of the NSO Certificate as proof of filiation.
Petitioners contested this reliance, filing a Motion for Reconsideration which was ultimately denied by the CA.

Petitioners challenged the validity and authenticity of the NSO Certificate, arguing that it was a reconstructed document based on the 1978 Certification rather than the original 1920 Record Book.
They contended that the certificate is suspect because it did not demonstrate any direct intervention, acknowledgment, or signature by the putative father, Ireneo.
Additionally, petitioners argued that the marriage contract merely established the celebration of a marriage and did not confirm paternity.
These issues formed the crux of the petition for review, with petitioners emphasizing that the lower courts erred in their evidentiary assessment and conclusions.

Whether the CA correctly held that respondents established the filiation of Silvestre to Ireneo, thereby entitling respondents to a share in Ireneo’s estate.

Is the NSO Certificate, reconstructed on the basis of the 1978 Certification, valid and sufficient proof of filiation?
Does the absence of Ireneo’s direct intervention (such as his signature on the certificate) undermine its probative value?
Can a reconstructed document without reference to the original 1920 Record Book be relied upon to conclusively establish paternity or filiation?