Case Summary (G.R. No. 95386)
Factual Background
The relationship between Manuel Ong and Saturnina Caballes began around December 20, 1953, leading to the birth of Alfredo Ong, Jr. on June 28, 1955, and Robert Ong on August 17, 1956. Manuel initially provided some financial support until he cut ties, prompting Saturnina to seek help for their children. She eventually filed for recognition and support, claiming that Manuel Ong had refused her requests despite acknowledgments in earlier instances.
Legal Proceedings and Trial Court Ruling
In a trial, the Regional Trial Court found that Alfredo Ong and Robert Ong were illegitimate children of Manuel Ong based on the provisions of Article 283 of the Civil Code, which stipulates the obligations of a father to recognize and support his child if the conditions are met. The court ordered Manuel Ong to provide monthly support to the plaintiffs, a decision which the Court of Appeals affirmed.
Appellate Court's Findings
The Court of Appeals affirmed the trial court’s findings, asserting that evidence supported the respondents' claims of their relationship with Manuel Ong. It referenced several paragraphs of Article 283, particularly focusing on continuous possession of status as children and circumstances of conception.
Arguments Presented by Petitioner
Miguela Campos Ong challenged the decisions on the grounds of Saturnina Caballes's credibility and morality, citing a past relationship with another man before her affair with Manuel Ong. The petitioner argued that the conditions outlined in Article 283 were not satisfied, particularly pointing to the lack of continuous recognition and support from Manuel Ong as evidence against the claims of paternity.
Court's Analysis of Evidence
The Supreme Court acknowledged the factual findings by the lower courts, emphasizing that their determinations on witness credibility carry significant weight. It found that minor inconsistencies in Saturnina Caballes’s testimony did not undermine the established fact of a relationship between her and Manuel Ong, especially given corroborative testimony from others.
Examination of Paternity Claims
The Court addressed the claims of Manuel Ong's alleged sterility, highlighting the absence of medical evidence and the past acknowledgment of another child he had, which contradicted the assertion that he could not father children. It reaffirmed that the burden of proof regarding virility rested with the petitioner.
Conclusion on Recognition and Support Oblig
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Case Overview
- This case involves a petition for review filed by Miguela Campos Ong, the surviving spouse of Manuel Ong.
- The petition seeks to challenge the decision of the Court of Appeals dated January 26, 1990, which affirmed the Regional Trial Court's ruling that recognized Alfredo Ong, Jr. and Robert Ong as the illegitimate children of Manuel Ong, thus entitled to support.
- The petitioner also contests the resolution denying her motion for reconsideration on August 16, 1990.
Background of the Parties
- Petitioner: Miguela Campos Ong, surviving spouse of Manuel Ong, who died on May 21, 1990.
- Respondents: Alfredo Ong, Jr. and Robert Ong, alleged illegitimate children of Manuel Ong, born to Saturnina Caballes.
Factual Context
Relationship Development:
- Manuel Ong, under the alias Alfredo Go, met Saturnina Caballes at Yarrow Beach Resort on December 20, 1953.
- They commenced a relationship, leading to cohabitation from October 1954 to March 1957.
- Two children were born from this relationship: Alfredo Ong, Jr. (born June 28, 1955) and Robert Ong (born August 17, 1956).
Support and Acknowledgment:
- Manuel Ong provided financial support to Saturnina and their children initially, which diminished over time.
- Attempts by Saturnina to obtain continued support from Manuel Ong were met with refusal.
Legal Proceedings:
- In September 1982, Alfredo Ong, Jr. filed a complaint for recognition and support against Manuel Ong, which was later amend