G.R. No. L-16307. April 30, 1963.
FEDERICA ABALLE, in her behalf and in behalf of her minor sons, RODOLFO SANTIAGO and JUNE JOSE SANTIAGO, plaintiffs-appellants, vs. FORTUNATO SANTIAGO, defendant-appellee.

FACTS

Federica Aballe filed an action for support, successional rights, and moral damages on behalf of her two minor sons, Rodolfo and June Jose Santiago, against Fortunato Santiago. She alleged that she cohabited with the defendant from 1947, resulting in the birth of Rodolfo in 1948 and June Jose in 1953. She presented baptismal certificates for the children and various unsigned notes (Exhibits C to K) purportedly from the defendant. She claimed she only discovered the defendant was already married after the birth of the second child, leading to their separation.
The defendant, Fortunato Santiago, categorically denied all allegations. He specifically denied paternity of the minors, denied authoring the notes, and denied performing any act acknowledging the children as his illegitimate offspring. The trial court dismissed the complaint, finding that the plaintiff failed to substantiate her claims with sufficient evidence.

ISSUE

Did the trial court err in dismissing the complaint for failure to prove filiation and, consequently, the right to support and successional rights?

RULING

No, the trial court did not err. The Supreme Court affirmed the dismissal. The appellants argued that the defendant’s failure to specifically deny the material evidence constituted an implied admission. This argument fails. The defendant, in his answer, explicitly stated he had no knowledge of the averments and specifically denied the causes of action. At trial, he denied the plaintiff’s entire testimony and the exhibits. Therefore, the rule on admission by silence is inapplicable.
Furthermore, the appeal was brought directly to the Supreme Court, which treats the case as raising only questions of law. The factual findings of the trial court are thus binding. The trial court correctly found the evidence insufficient. The baptismal certificates are not authentic documents to prove filiation for successional rights. The unsigned notes were fragmentary, contained no clear signatures or initials, and made no reference to the minors being the defendant’s children. The plaintiff’s uncorroborated testimony was squarely denied by the defendant. The long delay in filing the action, nearly seven years after learning of the defendant’s marriage, further undermined her credibility. With filiation not duly proved, the claims for support, successional rights, and moral damages necessarily fail. The decision was affirmed.