G.R. No. 1884. September 7, 1905
PRESENTACION INFANTE, guardian of the minor child MANUELA INFANTE, plaintiff-appellee, vs. MANUEL T. FIGUEREAS, defendant-appellant.

FACTS:
Presentacion Infante, as guardian of her minor daughter Manuela Infante, filed an action against Manuel T. Figuereas to compel him to recognize Manuela as his natural daughter under Article 135(2) of the Civil Code, which requires the child to be in continuous possession of the status of a natural child justified by acts of the father or his family. During the trial, the court admitted, over the defendant’s objection, testimonial evidence from the child’s grandmother (Pilar Chavez), mother (Presentacion Infante), and wet nurse (Natividad Coronada de la Cruz) concerning the intimate relations between the defendant and the mother prior to the child’s birth and specifically stating that the defendant was the father. The lower court ruled in favor of the plaintiff, and the defendant appealed, assigning as error the admission of this evidence.

ISSUE

Whether, in an action to compel recognition of a natural child based on continuous possession of status under Article 135(2) of the Civil Code, it is admissible to present evidence of the carnal relations between the mother and the alleged father and other proof directly aimed at investigating or proving biological paternity.

RULING

No. The Supreme Court reversed the judgment of the lower court and remanded the case for a new trial. The Court held that under the Civil Code, following the Law of Bases, the investigation of paternity is strictly limited to the specific cases enumerated in Article 135. In a case based on paragraph 2 (continuous possession of status), the only admissible evidence is that which directly proves the external acts of the father or his family demonstrating that the child was treated and regarded as a natural child. Evidence introduced for the purpose of proving biological paternity through testimony about prior relations is inadmissible. To allow such evidence would effectively permit the investigation of paternity, which the law prohibits except in the narrow instances provided. The Court cited authoritative Spanish commentators (Manresa, Alcubilla, Comas, and Scaevola) and jurisprudence to affirm that the obligation of the father arises solely from proof of the facts in Article 135(1) or (2), not from the mere fact of biological fatherhood. The improperly admitted evidence was prejudicial as it likely influenced the trial court’s finding on possession of status.