Case Summary (G.R. No. 85723)
Procedural History
On October 15, 1986, the action was filed by Clarito Agbulos, and during the trial, his mother, Felicitas Agbulos Haber, was presented as a witness. An objection from the defendant's counsel regarding her testimony concerning the identity of the father was sustained by the trial court. Following this, a petition for certiorari was filed with the Court of Appeals, which ultimately led to a decision on November 2, 1988, that allowed the testimony.
Grounds for Appeal
In the subsequent petition for review on certiorari, Rodriguez argued that the Court of Appeals erred in failing to dismiss the appeal on the grounds that the trial court's order was interlocutory. He contended that the appellate court should not have reversed the trial court’s decision allowing testimony regarding Agbulos' paternity. He claimed that according to Rule 65 of the Revised Rules of Court, errors not related to the court's jurisdiction or involving grave abuse of discretion are generally not reviewable.
Exceptions to General Rules
The court noted that exceptions to this rule exist, particularly when denial of certiorari could result in irreparable harm or a miscarriage of justice. The appellate court had determined that excluding the testimony in question could deprive the respondent of an adequate remedy.
Legal Provisions Invoked
Rodriguez contended the prohibition of disclosing the identity of the father under Article 280 of the Civil Code, which states that if one parent acknowledges a child separately, they must not reveal the name of the other parent. Conversely, Agbulos cited Article 283, which specifies circumstances under which a father is legally bound to recognize his child, as well as Section 30, Rule 130 of the Revised Rules of Court regarding the admissibility of witness testimony.
Evaluation of Jurisprudence
The court found that prior rulings, such as in Navarro v. Bacalla, did not apply in this instance as the defendant had not formally accepted the mother’s testimony during the initial trial. It was emphasized that the interpretation of Article 280 may not necessarily prevent the identification of the father in cases of compulsory recognition.
Historical Context of Legal Provisions
The court analyzed the historical legislation surrounding paternity and recognition, tracing the evolution from the Spanish Civil Code to the current provisions in the Philippine Civil Code, which ultimately indicate a shift toward allowing greater inquiry into the paternity of children, especially following the enactment of the Family Code.
Legislative Intent and Concl
...continue readingCase Syllabus (G.R. No. 85723)
Case Overview
- The case concerns a petition for review on certiorari under Rule 45 of the Revised Rules of Court.
- The petition was filed by Bienvenido Rodriguez against the Court of Appeals and Clarito Agbulos regarding a decision that allowed testimony concerning the identity of a putative father in a compulsory recognition action.
- The decision being reviewed was issued on November 2, 1988, by the Court of Appeals in CA-G.R. SP No. 14276.
Procedural Background
- The action for compulsory recognition and support was initiated on October 15, 1986, by Clarito Agbulos against Bienvenido Rodriguez in the Regional Trial Court, Branch 9, Baguio-Benguet.
- During the trial, Clarito's mother, Felicitas Agbulos Haber, was presented as a witness to identify the father of the plaintiff, but the defendant’s counsel objected, which the trial court sustained.
- Clarito subsequently filed a petition for review questioning the trial court's order, which was eventually referred to the Court of Appeals.
Issues Raised
- The petitioner alleged two main errors by the Court of Appeals:
- The court's failure to dismiss the petition for certiorari, arguing that the trial court's order was interlocutory and not subject to separate review.
- The court’s decision to reverse the trial court's order and allow the admission of Felicitas' testimony regarding the father's identity.
Legal Principles
- The case discusses the nature of certiorari under Rule 65, not