Title
Vda. de Clemena vs. Clemena
Case
G.R. No. L-24739
Decision Date
May 22, 1969
A widow and children contested an alleged illegitimate child's claim to inheritance, asserting exclusive jurisdiction of intestate proceedings; Supreme Court ruled in their favor, denying the claim and overturning the lower court's decision.

Case Summary (G.R. No. L-24739)

Factual Background

On July 13, 1965, the petitioners filed a special civil action for certiorari and prohibition against the respondent Judge regarding a motion to dismiss that had been denied. Agustin Engracio Clemena had sought an order compelling Adela Ongsiaco Vda. de Clemena to provide an inventory and accounting of the conjugal properties, as well as the partition of the estate. The petitioners contested the jurisdiction of the court, arguing that the Court of First Instance of Manila had exclusive jurisdiction over the estate's settlement.

Legal Arguments

The petitioners contended that the action brought by Agustin Engracio Clemena should have been dismissed as it was filed in the wrong court, given that it was related to the settlement of the estate, which was already being handled by another court. They argued that the ongoing proceedings invalidated Agustin's claim as he lacked standing to pursue the action based on existing jurisprudence regarding the rights of illegitimate children.

Judicial Findings

The court highlighted a previous decision rendered on August 22, 1968, which stated that an illegitimate child must act within the time limits prescribed by Article 285 of the Civil Code for establishing paternity. The ruling indicated that allowing Agustin Engracio Clemena to pursue a legal declaration of paternity at this stage would disrupt the legal classifications established in the Civil Code and provide him an undue advantage over legitimate and natural children.

Conclusion

Ultimately, the court determined that Agustin Engracio Cleme

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