Case Summary (G.R. No. 177875)
Procedural History and Relevant Dates
- September 6, 1995: Divina Buling filed a complaint for compulsory recognition and support pendente lite against Charles Gotardo.
- March 9, 1995: Birth of Gliffze O. Buling.
- June 25, 2002: RTC rendered a decision dismissing the complaint.
- March 5, 2004: Court of Appeals (CA) reversed RTC decision and ordered the petitioner to recognize and support Gliffze.
- July 27, 2004: CA denied petitioner’s motion for reconsideration.
- August 15, 2012: Supreme Court decision affirming CA ruling.
Factual Background
The respondent met petitioner at the Philippine Commercial and Industrial Bank, Maasin branch, where she was a casual employee and he was an accounting supervisor. Their courtship began in December 1992, with a courtship established by January 1993. The petitioner and respondent engaged in intimate sexual relations starting September 1993, occurring approximately twice a month, becoming more frequent by June 1994. Respondent discovered her pregnancy on August 8, 1994. The petitioner was initially happy, planned to marry her, and even applied for a marriage license, but later withdrew from wedding plans. Respondent filed a breach of promise to marry complaint, which was later amicably settled. The petitioner failed to recognize or support the child after birth, prompting the filing of the paternity and support case.
Issues Presented
Whether the Court of Appeals committed a reversible error in overturning the RTC's dismissal of the compulsory recognition and support complaint, and whether there exists sufficient evidence to establish the petitioner’s paternity of Gliffze.
RTC’s Findings
The RTC dismissed the complaint due to alleged inconsistencies in the respondent’s testimony, particularly concerning the timing of their first sexual contact. The court also questioned the reasonableness of continuing sexual relations even after the respondent had refused the petitioner’s initial marriage proposal. The RTC ordered the return of support payments and awarded attorney’s fees against the respondent.
Court of Appeals Ruling
The CA set aside the RTC ruling, explaining that the supposed inconsistencies were due to the respondent’s misunderstanding of counsel’s questions rather than deliberate falsehoods. It found that the petitioner and respondent had an ongoing sexual relationship prior to August 1994, and there was no substantiation of the petitioner’s allegations that the respondent had relations with other men. The CA therefore ordered petitioner to recognize his son and provide monthly support of P2,000.00, reinstating the RTC’s prior child support order.
Supreme Court’s Analysis on Evidentiary and Legal Considerations
- Prima Facie Case and Burden of Proof: The respondent successfully established a prima facie case by testifying that she engaged in sexual relations only with the petitioner during the period of conception. This shifted the burden to the petitioner to provide affirmative defenses such as impotence or the mother’s infidelity, which were not substantiated.
- Proof of Filiation: Beyond the civil register or judicial declaration, filiation may be proven by various admissible evidence under the Rules of Court, including witness testimonies and other corroborative documents.
- Credibility of Witness: The Court emphasized the importance of evaluating testimony in totality, not by isolated inconsistent parts. The respondent’s contradictions were found to be mostly apparent, explained as misunderstandings or transcription errors, and did not detract from the credibility of her testimony overall.
- Support Obligation: Given the established filiation, the petitioner’s duty to provide support for the child is mandatory under the Family Code. The amount awarded—P2,000.00 monthly—was reasonable in view of the needs of the child and the petitioner’s capacity, subject to modification if circumstances change.
Final Ruling
The Supreme Court affirmed the Court of Appeals decision, denying the petitioner’s petition for review for lack of merit. The Court upheld the order for compulsory r
Case Syllabus (G.R. No. 177875)
Procedural History and Nature of the Petition
- The case involves a petition for review on certiorari filed by Charles Gotardo to challenge the March 5, 2004 decision and the July 27, 2004 resolution of the Court of Appeals (CA), which ordered the petitioner to recognize and provide legal support to his minor son, Gliffze O. Buling.
- The petitioner’s motion for reconsideration was denied by the CA.
- The Regional Trial Court (RTC) of Maasin, Southern Leyte, Branch 25, originally heard the case on compulsory recognition and support pendente lite filed by respondent Divina Buling.
- The petitioner denied paternity, leading to trial after failed amicable settlement.
Factual Background
- Respondent Divina Buling filed a complaint dated September 6, 1995, alleging petitioner as the father of her child, Gliffze.
- Both parties were employees at the Philippine Commercial and Industrial Bank, Maasin: respondent as casual employee, petitioner as accounting supervisor.
- Court testimony reveals they met on December 1, 1992, with courtship starting in late December 1992, and romantic relationship established by late January 1993.
- They had intimate sexual relations beginning approximately September 1993 in a rented boarding room; evidence clarified sexual encounters increased in frequency by June 1994.
- Respondent discovered pregnancy on August 8, 1994, and petitioner initially expressed happiness and plans to marry, including applying for a marriage license and inquiring about wedding costs.
- Petitioner eventually withdrew from marriage plans; respondent filed a breach of promise to marry complaint, later settled amicably.
- The child, Gliffze, was born March 9, 1995.
- Petitioner failed to provide support, prompting respondent to send a demand letter on July 24, 1995, followed by filing the complaint for compulsory recognition and support pendente lite.
- Petitioner denied paternity at trial alleging first sexual contact was only in early August 1994, making the pregnancy timeline medically impossible.
Trial Evidences and Testimonies
- Respondent testified personally, with Rodulfo Lopez, her uncle and witness, corroborating the existence of an intimate relationship.
- Respondent’s testimony indicated continuous and exclusive sexual relationship with petitioner during the relevant period.
- Petitioner admitted sexual relations with respondent but alleged they occurred later than claimed, contesting the pregnancy tim