Case Summary (G.R. No. L-12894)

Motion for Reconsideration Overview

• The defendant-appellee filed a motion for reconsideration regarding a previous decision by the Court.
• The prior decision reversed the dismissal of the plaintiffs' complaint for declaration or investigation of paternity based on the grounds of prescription.

Legal Basis for Plaintiffs' Action

• The plaintiffs' action is authorized under Article 289 of the new Civil Code, which allows for the investigation of paternity of illegitimate children.
• The Court compared this action to the recognition of natural children under Article 285, which permits such actions during the lifetime of presumed parents, with specific exceptions for posthumous claims.

Time Limitations for Actions

• The Court ruled that the same time limitations apply to both actions due to their similarities, unless explicitly stated otherwise in the law.
• The defendant-appellee contended that the action for spurious paternity must be initiated within five years as per Article 1149 of the Civil Code, rather than the periods specified in Article 285.

Rejection of Defendant's Arguments

• The Court found the defendant's arguments untenable, affirming that Article 285 clearly limits the action for recognition of natural children.
• Previous rulings by the Court confirmed that actions under Article 285 prescribe if not filed during the parent's lifetime, barring certain exceptions.

Public Policy Considerations

• The Court noted that public policy is a significant factor in actions for the acknowledgment of natural children.
• A reference to a Supreme Court of Spain decision highlighted that actions for the recognition of natural children are subject to specific conditions that are public in nature, distinct from general prescription rules.

Clarification on Prescription Periods

• Article 1148 of the Civil Code states that limitations of actions in one part of the Code do not affect those specified in other parts.
• The Court maintained that the time limitation in Article 285 for natural children also applies to spurious children, without granting spurious children greater rights than natural children.

Reference to Judicial Opinion

• The defendant-appelle...continue reading

Case Syllabus (G.R. No. L-12894)

Case Overview

• The case centers on a petition filed by Lilia Juana Barles, Maria Estrella Barles, and Remedios Baeles, who sought recognition of their paternal affiliation with Don Alfonso Ponce Enrile, their alleged father.
• The plaintiffs claimed to be the illegitimate children of the defendant and Genoveva Barles, their natural mother, asserting that the defendant cohabited with their mother at the time of their conception and birth.
• The initial filing occurred on September 1, 1955, in the Court of First Instance of Manila, seeking recognition and damages for moral injury.

Procedural History

• Upon receiving the complaint, instead of providing an answer, the defendant filed a motion to dismiss, arguing that the complaint failed to state a cause of action and was barred by prescription.
• The court deferred action on the motion until after trial, leading to the defendant eventually filing an answer.
• The case was later transferred to the newly established Juvenile and Domestic Relations Court under Republic Act No. 1401.
• On June 1, 1957, the Juvenile and Domestic Relations Court dismissed the complaint, concluding that while the complaint stated a valid cause of action, it was barred by prescription.
• The plaintiffs' motion for reconsideration was denied, prompting them to appeal directly to the Supreme Court of the Philippines.

Supreme Court Findings

• The Supreme Court found merit in the plaintiffs' appeal, focusing on the misapplication of the la...continue reading