Case Summary (G.R. No. 200169)
Relevant Dates and Case History
- Petitioner filed a civil case in June 1996 seeking a mandatory injunction and damages after the disappearance and subsequent possession of the titles by respondent.
- The Regional Trial Court (RTC) of Bacolod City dismissed petitioner’s complaint on August 17, 1999.
- The Court of Appeals (CA) affirmed the RTC decision on August 30, 2006, and denied petitioner’s Motion for Reconsideration on December 20, 2011.
- The Supreme Court issued its decision on January 28, 2015, under the 1987 Philippine Constitution.
Legal Framework
The applicable law includes Article 172 of the Family Code, which governs the establishment of filiation (parent-child relationship) of legitimate children, allowing proof through: (1) birth records or final judgment; (2) an admission of legitimate filiation in a public document or a private handwritten instrument signed by the parent concerned; or (3) in the absence of such, proof through open and continuous possession of the status of a legitimate child or other lawful means. Also relevant are Articles 170 and 171 of the Family Code concerning the prescriptive period to impugn legitimacy.
Factual Summary and Evidence Presented
Petitioner asserted that he is the legitimate son and sole heir of the deceased Aguilar spouses. To prove filiation, petitioner submitted various documents: school records listing Alfredo Aguilar as his parent; his income tax return indicating Candelaria Siasat-Aguilar as his mother; Alfredo Aguilar’s sworn Social Security System (SSS) Form E-1 recognizing petitioner as his son; employment records of Alfredo Aguilar listing petitioner as his dependent; petitioner’s marriage certificate declaring the Aguilar spouses as parents; and testimonies from petitioner’s wife and Alfredo Aguilar’s sister affirming petitioner’s filial relationship and sole heirship. Petitioner explained that the local registry records were destroyed and hence he could not produce a Certificate of Live Birth.
In contrast, respondent denied petitioner’s filiation, claiming he was raised by the Aguilar spouses but was not their biological or legally adopted child. She presented an affidavit by Candelaria Siasat-Aguilar declaring she had no issue and was sole heir, and testimonies from family members supporting her version. Respondent contended the subject titles were entrusted to her, not stolen, and challenged petitioner’s legitimacy and heirship claim.
RTC Ruling
The RTC dismissed petitioner’s complaint, reasoning that petitioner failed to present solid proof of filiationship. The absence of a Certificate of Live Birth and the affidavit of Candelaria Siasat-Aguilar stating there was no issue deprived petitioner of legal interest to maintain his action. The RTC also dismissed respondent’s counterclaim.
Court of Appeals Ruling
The CA affirmed the RTC decision, categorically ruling that petitioner’s submitted documentary evidence, including the school records, income tax returns, marriage certificate, and employment records, were insufficient to prove filiation, citing established jurisprudence that such documents do not conclusively prove legitimate filiation. Regarding the SSS Form E-1 executed by Alfredo Aguilar recognizing petitioner as his son, the CA held that the document did not meet the clear and convincing standard of proof to establish filiation, treating it as mere evidence of possession of status rather than recognition in a public document under Article 172 of the Family Code. The CA also found that petitioner failed to prove a clear right to the title documents and thus was not entitled to injunction or damages.
Issues Raised in the Petition for Review
The core issue is whether Alfredo Aguilar’s SSS Form E-1, a sworn public document recognizing petitioner as his son, satisfies the requirement under Article 172 of the Family Code to establish legitimate filiation without the need for judicial action. The petitioner argues that such document constitutes conclusive proof of filiation as an admission in a public document, thereby entitling him to the ownership of the disputed titles and granting the requested injunctive relief and damages.
Petitioner’s Arguments
Petitioner highlights that the SSS Form E-1 is a notarized acknowledgment by his father under oath declaring their filiation, which under Article 172, is valid proof of legitimate filiation, superseding the need for birth certificates or additional prescriptive actions. He contends that respondent lacks standing to question his legitimacy, and that the prescriptive period to impugn legitimacy has long expired. Petitioner urges the Court to reverse the lower courts’ decisions and recognize his sole heirship of the properties, ordering respondent to surrender the titles.
Respondent’s Arguments
Respondent maintains the CA’s ruling and contends that the petition merely rehashes previous claims, lacking merit and sufficient evidence binding on petitioner’s filiation. She continues to assert non-filiation and lawful possession of the titles.
Supreme Court’s Analysis and Decision
The Supreme Court granted petitioner’s petition, affirming the doctrine set forth in De Jesus v. Estate of Dizon that establishes filiation of legitimate children may be proved by an admission in a public document or a private handwritten instrument signed by the parent concerned, which in itself is a consummated act of acknowledgment requiring no further judicial approval.
The Court emphasized the presumption of legi
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Case Background and Facts
- Petition for Review on Certiorari filed by Rodolfo S. Aguilar seeks to overturn the decisions of the Court of Appeals and the Regional Trial Court concerning ownership and possession of two parcels of land covered by Transfer Certificates of Title Nos. T-25896 and T-(15462) 1070.
- The subject properties belonged to spouses Alfredo Aguilar and Candelaria Siasat-Aguilar, who died intestate and without debts in 1983 and 1994 respectively.
- Petitioner claimed to be the only son and sole surviving heir of the Aguilar spouses, alleging that the subject titles were missing and possibly stolen by members of the Siasat clan.
- Petitioner executed affidavits of loss for the titles and filed a Petition for issuance of second owner’s copies of the title, which respondent opposed, but later respondent produced duplicates of the subject titles.
- Petitioner filed a civil case for mandatory injunction ordering respondent to surrender the duplicate copies and for damages.
- Respondent denied petitioner’s filiation, claiming petitioner was a stranger raised by the Aguilar spouses, not their natural or adopted son; claimed ownership of the properties via inheritance from her aunt Candelaria Siasat-Aguilar.
- Respondent asserted the titles were entrusted to her by Candelaria, not stolen, and counterclaimed for damages and attorney’s fees.
Evidence Presented by Petitioner
- Petitioner testified as son of the Aguilar spouses and introduced multiple documentary evidences including:
- School records indicating Alfredo Aguilar as parent.
- Individual Income Tax Return listing Candelaria Siasat-Aguilar as mother.
- Alfredo Aguilar’s Social Security System (SSS) Form E-1 dated 1957, notarized and under oath, which recognized petitioner as his son and dependent.
- Employment information sheet of Alfredo Aguilar referencing petitioner as son.
- Petitioner’s marriage certificate declaring Aguilar spouses as parents.
- Letter from Bacolod Milling Company secretary introducing petitioner as Alfredo’s son.
- Bacolod City Civil Registry certified that birth records for 1945 to 1946 were destroyed, preventing petitioner from producing a certificate of live birth.
- Testimonies from petitioner’s wife, Luz Marie Abendan-Aguilar, confirming petitioner’s identity and filiation; they lived in the conjugal home built on the disputed properties.
- Testimony from petitioner’s aunt, Ester Aguilar-Pailano, confirming petitioner as the sole child of the Aguilar spouses, and recognized as sole heir after their deaths.
Evidence Presented by Respondent
- Respondent testified she was a retired teacher, not related to petitioner, and had custody of the subject titles, which were entrusted to her by her aunt, Candelaria Siasat-Aguilar.
- Respondent asserted petitioner was not the son of the Aguilar spouses and denied knowledge of petitioner beyond hearsay.
- Offered testimony of Aurea Siasat-Nicavera, sister of Candelaria, denying petitioner’s filiation.
- Presented an affidavit executed by Candelaria Siasat-Aguilar expressly stating they had no issue and Candelaria was the sole heir to Alfredo’s estate.
- Claimed a planned sale of the properties was aborted due to petitioner’s objection.
Regional Trial Court (RTC) Decision
- Dismissed petitioner’s complaint and counterclaim.
- Concluded petitioner failed to present solid evidence, especially a certificate of live birth, proving he was either biological o