G.R. No. 50974-75 May 31, 1989
JUAN CASTRO and FELICIANA CASTRO, petitioners, vs. HON. COURT OF APPEALS, CIPRIANO NAVAL and BENITA C. NAVAL, respondents.

FACTS

Petitioners Juan and Feliciana Castro, siblings of the late Eustaquio Castro, and Marcelina Bautista, Eustaquio’s surviving spouse, filed separate complaints for partition against respondent Benita Castro Naval, claiming to be compulsory heirs of Eustaquio. The actions were later converted into actions for quieting of title. Benita, assisted by her husband Cipriano Naval, claimed she is the sole heir as the acknowledged illegitimate child of Eustaquio. The parties stipulated that the central issue was whether Benita was indeed the acknowledged natural child of Eustaquio Castro.
The evidence established that Benita was born on March 27, 1919, to Eustaquio Castro and Pricola Maregmen. Eustaquio himself registered the birth, stating he was the father. Benita’s baptismal certificate also named Eustaquio and Pricola as her parents. Eustaquio and Pricola lived together as husband and wife from 1913 until Pricola’s death in 1924, as Pricola had left her forced marriage to another man. Eustaquio, a widower at the time, was legally free to marry. Benita lived with and was supported by Eustaquio, who also gave her away at her wedding. She was treated as his child within the family and community.

ISSUE

Whether Benita C. Naval is a duly acknowledged illegitimate child of the late Eustaquio Castro, thereby entitling her to inherit from him.

RULING

Yes. The Supreme Court affirmed the decisions of the lower courts recognizing Benita as Eustaquio’s acknowledged illegitimate child. The legal logic proceeds from the evidence of continuous possession of status and the retroactive application of the Family Code. Under the old Civil Code, which governed at the time of Eustaquio’s death, acknowledgment of a natural child could be made in a record of birth, a will, or other public document. The Court found that Eustaquio’s act of registering Benita’s birth and stating he was the father constituted a public acknowledgment. Furthermore, Benita’s open and continuous possession of the status of an illegitimate child was convincingly proven by her living with and being supported by Eustaquio, his giving her away at her wedding, and her acceptance as his daughter within the family, as evidenced by her presence at his wake.
To resolve any lingering doubts, the Court applied the Family Code retroactively, as no vested rights of the petitioners were impaired. The Family Code simplifies filiation into legitimate and illegitimate classes and allows illegitimate children to establish filiation by the same evidence as legitimate children. Article 172 of the Family Code recognizes open and continuous possession of status as proof of filiation. Benita’s lifelong possession of the status of Eustaquio’s child, coupled with his public acknowledgment in the birth record, satisfies this standard. Her defense of her status in this case is equivalent to a timely action to claim filiation. Therefore, she is rightfully declared Eustaquio’s heir to the exclusion of the petitioners.