Case Summary (G.R. No. 104376)
Factual Background and Relationship History
Leoncia de los Santos met Artemio G. Ilano in 1957 during her work as a business manager and resumed contact with him, who was engaged in a similar business. Over a period exceeding four years, their relationship became intimate and was accompanied by petitioner’s promise of marriage. They eloped in April 1962 and lived together intermittently as husband and wife in various locations, including an apartment in Guagua, Pampanga procured and managed by Melencio Reyes, a subordinate of petitioner, who also took care of household errands and bills. Petitioner provided monthly expenses, approximately P700, reflecting his support for Leoncia and later, for Merciditas, their daughter born on December 30, 1963.
Evidence of Paternity and Domestic Relations
Various forms of support were documented, including cash payments, checks, and personal gifts. The petitioner was actively involved in Merciditas’ life, signing her school report cards and treating her with paternal affection. He was recognized by the child as "Daddy" and engaged in activities typical of a father. Despite such evidence, petitioner contested all claims of paternity and denied any relationship with Leoncia and Merciditas, including repudiating important documents and testimonies. Contradictory evidence presented by family members and subordinates corroborated the respondent's claim that petitioner lived with Leoncia and supported Merciditas until 1971.
Trial Court Ruling
The trial court dismissed the complaint, citing lack of proven cohabitation during Merciditas’ conception, testimony of Melencio asserting his intimacy with Leoncia, absence of petitioner’s signature on Merciditas’ birth certificate, denial of recognition by petitioner, and insufficient evidence of support. The court questioned the credibility of the respondent’s evidence to establish filiation and paternity.
Court of Appeals Ruling
The Court of Appeals reversed the trial court’s decision, finding overwhelming evidence of petitioner’s paternity and acknowledging that Merciditas is entitled to support as an illegitimate child. The court highlighted petitioner’s continuous manifestation of paternal recognition through financial support, personal care, acknowledgment in school documents, and acts of affection. It discredited testimonies suggesting petitioner’s non-involvement, particularly the testimony of Melencio, whom it characterized as subservient and untruthful regarding the nature of his relationship with Leoncia. The appellate court also applied relevant articles of the Civil Code to establish recognition of paternity beyond doubt.
Legal Principles on Illegitimate Children and Recognition of Paternity
Under the Civil Code, illegitimate children are classified as either natural or spurious (which includes adulterous children). Merciditas, conceived while the petitioner was married to another woman, is categorized as a spurious child. Article 287 mandates that spurious illegitimate children are entitled to support upon recognition of paternity, which can be voluntary or judicial. Recognition is fundamental in establishing rights since filiation for illegitimate children is based legally not on bloodline alone but on acknowledgment by the parent.
Article 283 details circumstances obliging the father to recognize a child, including “continuous possession of status of a child” and evidence supporting paternity. The Court emphasized multiple forms of proof: the petitioner’s acts of support, recognition through signatures on birth and school records, and his treatment of Merciditas as a legitimate child. Evidence of direct paternal acts and support fulfills the standard of recognition required by law, making revocation impossible after judicial acknowledgment due to the principle of stability of civil status.
Additional Considerations and Rebuttal of Petitioner’s Arguments
Arguments raised by petitioner contesting recognition and support were addressed exhaustively. The petitioner’s claim of his absence during conception and delivery, and denial of signatures or relationships, were dismissed as implausible in light of the body of contradictory and consistent evidence. Claims that Merciditas as an adulterous child could not sue for recognition were invalidated, citing Article 287 affirming spurious children’s entitlement to support. The evidence showed clear acts of recognition and support, which the petitioner sought to negate without sufficient basis.
Basis of the Support Award and Calculation
The Court of Appeals awarded support arrears computed from the complai
...continue readingCase Syllabus (G.R. No. 104376)
Background and Facts of the Case
- Leoncia de los Santos first met Artemio G. Ilano when she worked as a secretary to Atty. Mariano C. Virata, Ilano being a client of Atty. Virata.
- Over time, Leoncia and Artemio developed a closer relationship marked by dining together multiple times and resumed contact in 1957 when both were involved in the Namarco distribution business.
- Artemio supplied Leoncia with his unsold allocation of goods and courted her for over four years.
- They eloped in April 1962 to Guagua, Pampanga, residing together at La Mesa Apartment where Artemio was president and general manager of the Filipinas Telephone Company branch.
- Melencio Reyes, Officer-in-Charge of the said telephone company, procured and managed the apartment on Artemio's behalf, including payments for rent and utilities. Melencio also provided Leoncia with a maid, as Leoncia was unfamiliar with the local dialect.
- Artemio gave Leoncia P700 monthly for household expenses.
- In June 1962, with Leoncia pregnant, Artemio fetched her, and they moved to San Juan Street, Pasay City.
- Leoncia delivered a stillborn female child in October 1962, with Artemio signing the death certificate.
- Subsequently, Merciditas S. Ilano, the private respondent, was born on December 30, 1963, registered as the child of Leoncia Aguinaldo de los Santos and Artemio G. Ilano.
- Leoncia was recorded as Mrs. Leoncia Ilano during her hospital confinement from December 30, 1963, to January 2, 1964.
- Support from Artemio to Leoncia and Merciditas was given through various means—cash personally delivered, through Melencio, Elynia (Leoncia’s niece), and even Merciditas herself—and by check, including Manila Banking Corporation Check No. 81532 which bore Artemio’s signature.
- Both Artemio and Merciditas admitted to the genuineness of his signature on said check.
- Artemio recognized Merciditas as his daughter by signing her Grade I report card and openly displaying paternal care such as bringing gifts, taking her on outings, and being called “Daddy” by her once she had discernment.
- Artemio exhibited personal affection and concern despite a complicated relationship, including providing Leoncia with a signed photograph devoted to "Nene."
- Artemio ceased visiting Leoncia and Merciditas in June 1971.
- Artemio denied any relationship with Leoncia and Merciditas, disputing signatures and receipts except admitting to the check signature.
- Witnesses, including Melencio (who denied intimate relations with Leoncia), overstated their roles, often acting under Artemio’s instructions.
- Artemio’s wife and daughter testified that Artemio was ill in December 1963, stayed at their family home, and did not live with Leoncia.
- The trial court initially dismissed the complaint, citing lack of cohabitation during Merciditas’ conception, Melencio’s testimony that he lived with Leoncia, lack of petitioner’s signature on Merciditas’ birth certificate, denial of signature on the report card, and insufficient evidence of support.
Proceedings and Court of Appeals Decision
- The Court of Appeals reversed the trial court's decision, declaring Merciditas the duly acknowledged and recognized illegitimate child of Artemio with right to support.
- It ordered Artemio to pay support in varying amounts covering the period from the complaint filing in 1972 until Merciditas reached majority in 1984, and awarded attorney’s fees and costs.
- The CA dismissed the petition for reconsideration filed by Artemio.
- Artemio then filed the present petition questioning the award of back support in the absence of formal recognition or final judgment on paternity, the inadmissibility of an adulterous child to sue for recognition, and the alleged disregard of established jurisprudence.
Legal Issues Presented
- Whether the award of back support was proper without a final judgment establishing paternity.
- Whether an adulterous (spurious) child can bring an action for recognition.
- Whether the Court of Appeals’ decision contravened established court rulings on the matter.
- Whether sufficient evidence existed to establish recognition or acknowledgment of Merci