Case Summary (G.R. No. 120587)
Procedural History
Nadina Maravilla, who was legally married to Francisco Maravilla, initiated a Petition for Correction of Entries in her daughter June Salvacion's birth certificate, asserting that Armando Gustilo was the father. The Regional Trial Court (RTC) in Makati granted the petition despite the standing legitimacy presumption of children born during a marriage. The Court of Appeals upheld the RTC's decision, dismissing subsequent petitions challenging the RTC's authority over the matter.
Jurisdictional Challenges
Milagros Barco challenged the RTC's jurisdiction by claiming she should have been made a party to the correction petition, arguing that her lack of involvement deprived the court of subject matter jurisdiction. The Court of Appeals affirmed that jurisdiction was acquired through proper notice by publication under Rule 108, which serves to bind all parties with interests in the outcome.
Prescriptive Period and Nature of the Action
Barco contended that Nadina's petition was filed out of the one-year prescriptive period governed by Article 263 of the Civil Code, which limits the time frame within which to contest the legitimacy of a child. The Court rejected this assertion, emphasizing that the RTC had jurisdiction over the subject matter nonetheless. Barco also attempted to categorize Nadina's petition as one for a name change, which could only be filed by the individual whose name was to be changed; however, the court maintained that the RTC lawfully addressed substantive corrections to the civil registry.
Examination of Legitimacy
The legitimacy of June Salvacion was central to this dispute. The court reaffirmed the legal presumption that children born during a valid marriage are legitimate, with any challenge requiring substantive proof of the biological father's paternity. The testimony provided by Nadina was deemed insufficient as evidence against this presumption. Notably, the appellate court held that the initial ruling to change June’s surname to Gustilo was flawed, asserting that as an illegitimate child she could not bear the father's surname.
Finality of Judgment and Annulment
The court focused on the requirements for annulment of judgments. Barco's attempts to demonstrate extrinsic fraud or lack of jurisdiction were deemed insufficient. The court highlighted that the distinction between lack of jurisdiction and mere errors in judgment must
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Case Background
- The case revolves around a complex familial situation involving claims of illegitimacy, judicial correction of civil registry entries, and the legitimacy of parentage.
- Petitioner Milagros M. Barco seeks to annul a Regional Trial Court (RTC) order that corrected the birth certificate of June Salvacion Gustilo, declaring Armando Gustilo as her father instead of Francisco Maravilla, Nadina Maravilla's former spouse.
- The RTC's decision was contested on multiple grounds, primarily focusing on jurisdiction and procedural issues.
Marriage and Birth Events
- Nadina Maravilla married Francisco Maravilla on December 24, 1970, but they separated in February 1977 and obtained an ecclesiastical annulment in 1978.
- Nadina gave birth to June Salvacion on June 9, 1978, with Francisco listed as the father on the birth certificate, which Nadina signed shortly after.
- Despite this, Nadina later claimed Armando Gustilo was June's biological father, with whom she married in the United States in 1982.
Petition for Correction of Birth Certificate
- On March 17, 1983, Nadina filed a Petition for Correction of Entries in June's birth certificate, asserting her separation from Francisco and the acknowledgment of Gustilo as June's true father.
- The petition was initially supported by Francisco's signature indicating his conformity, and Gustilo acknowledged June as his daughter without objection.
RTC Proceedings and Rulings
- The RTC set the petition for hearing and directed publication of the notice, which was done in compliance with Rule 108 of the Rules of Court.
- The Office of the Solicitor General filed a Motion to Dismiss, arguing that the RTC lacked jurisdictio