Title
Amurao vs. Court of Appeals
Case
G.R. No. 83942
Decision Date
Dec 29, 1988
Petitioner denied paternity but agreed to a blood test; results indicated possible paternity. Courts upheld support obligations, increasing payments based on child’s needs.

Case Summary (G.R. No. 83942)

Background of the Case

The petitioner, Romeo S. Amurao, faced a support suit initiated by the minor Romuel Jerome Buenaventura, arising from an alleged unlawful relationship. The petitioner contested his paternity and declined to provide financial support for the child. Upon commencement of the trial, a conference was held to simplify the issues, resulting in a mutual agreement to undergo a blood-grouping test to determine the plaintiff's paternity, with acknowledged binding consequences based on the test outcome.

Agreement on Blood-Grouping Test

Following the conference, the court issued an order stipulating the parties' agreement to undergo testing at the NBI, with specified conditions: should the results indicate a possibility of paternity, Amurao would acknowledge this and the trial would proceed solely on the matter of support; if the results were negative, the case would be dismissed without trial. The order was duly recorded and signed by all relevant parties.

Findings from the NBI Blood Test

The NBI's report on October 17, 1977, identified the child as a possible offspring of the petitioner, which the court subsequently factored into its proceedings. Despite this significant finding, Amurao filed a motion for reconsideration regarding the September 26, 1977 court order, claiming its invalidity. The trial court denied this motion, leading Amurao to seek a certiorari review from the Supreme Court, which was dismissed on May 4, 1980.

Contempt Proceedings and Judgment

Subsequent to the denial of the motion for reconsideration, a contempt motion was filed against Amurao due to his failure to comply with support obligations. During these proceedings, evidence was presented to assess Amurao's financial capability to support the minor. However, when summoned for a trial on July 8, 1983, Amurao and his counsel failed to appear, prompting the court to declare the case submitted for judgment. On August 8, 1985, the court ordered Amurao to pay monthly support and legal fees.

Appeals to the Court of Appeals

Amurao appealed the trial court's ruling to the Court of Appeals, which affirmed the trial court's decision on March 7, 1988, while increasing the monthly support amount. The petitioner's allegations of error in the Court of Appeals' decision centered on the purported admission of paternity, the consideration of trial evidence, and the increase in the support amount, invoking various articles of the Civil Code.

Court's Rationale on Appeal

The Supreme Court noted that disputed issues largely pertained to factual determinations that fell beyond the scope of its review under Rule 45 of the Rules of Court. It affirmed that

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