G.R. No. 98121-22 - People vs. Salazar y Rapis

Case Summary (G.R. No. 98121-22)

Factual Background

The relationship between the plaintiff and defendant began while the defendant was renting agricultural land and the plaintiff's father was employed by him. The couple had two children, both of whom the plaintiff claims the defendant fathered. Following the birth of her second child, the plaintiff discovered that the defendant was married to someone else, leading to their separation. She subsequently resided in a house purchased for her by the defendant. The defendant, however, refuted all claims regarding the children's paternity and the existence of any obligations toward them.

Procedural History

After a trial, the lower court dismissed the case, stating that there was insufficient evidence to establish a claim for support, successional rights, or moral damages. The plaintiffs, asserting that the defendant had implicitly admitted to the allegations by failing to deny them adequately, appealed the decision directly to the Supreme Court.

Admission by Silence

The appellants contended that since the defendant did not provide specific denial to the material evidence presented, this should be interpreted as an implied admission of the allegations. However, the court found that the defendant unequivocally denied knowledge of and responsibility for the claims. The failure to directly engage with the allegations submitted by the plaintiffs meant that the issue of implied admission did not apply.

Factual Submissions and Evidence

The court scrutinized the evidence presented, including baptismal certificates, notes, and other documents which the plaintiff claimed substantiated her claims. The baptismal certificates were deemed insufficient to establish paternity as they did not constitute legitimate proof. The notes were characterized as informal and lacking authenticating characteristics like signatures. The court concluded that the documentary evidence did not sufficiently establish the father’s acknowledgment of the children’s status as his illegitimate offspring.

Timeliness of the Complaint

It is noteworthy that the plaintiff did not take action against the defendant until June 1959, nearly seven years after learning of his marital status. This delay, coupled with the fact that she accepted the house given to her by the defendant, weakened her position significantly. The trial judge found that the inaction on her part illustrated a lack of urgency in asserting her claims.

Decision of the Supreme Court

The Supreme Court upheld the trial court’s decision, affirming the dismissal of the