G.R. No. 1362 : April 15, 1904
ROSA LLORENTE, plaintiff-appellant, vs. CEFERINO RODRIGUEZ, administrator of the estate of Jacinta Llorente, defendant-appellee.

FACTS:
Rosa Llorente filed an action against Ceferino Rodriguez, the administrator of the intestate estate of Jacinta Llorente, for the judicial partition and distribution of the estate. Rosa claimed to be a legally recognized natural daughter of the deceased and, therefore, an heir entitled to a share. The defendant, as administrator, opposed the petition. The Court of First Instance dismissed Rosa’s petition, ruling that the recognition of a natural child must be made strictly in accordance with Article 131 of the Civil Code (through a record of birth, a will, or a public instrument). Consequently, the trial court excluded all evidence offered by Rosa to prove her status, such as testimony and a baptismal certificate showing that Jacinta Llorente had reared, educated, and expressly authorized her baptism as a natural child, as well as proof from witnesses present at her birth.

ISSUE:
1. Whether the provisions of the Civil Code (specifically Article 131) govern the recognition of Rosa Llorente, who was born in 1872, prior to the Code’s effectivity in 1889.
2. If the old law (Law of Toro) applies, whether a mother had the legal capacity to recognize a natural child, or if that right was confined to the father.
3. If the mother had such capacity, whether the evidence excluded by the trial court was sufficient to establish a legal recognition.

RULING:
The Supreme Court reversed the judgment of the lower court and remanded the case for a new trial.

1. On the Applicable Law: The Court held that the law in force at the time of Rosa Llorente’s birth in 1872 governs the determination of her status as a recognized natural child. Applying the transitory provisions of the Civil Code (Article 1976), rights acquired under prior legislation are preserved. The status of a recognized natural child, once acquired, is a vested right that cannot be impaired by the new Code’s different procedural requirements for recognition.

2. On the Mother’s Capacity to Recognize: The Court ruled that under the old law (Law 11 of Toro), a mother could legally recognize her natural child. While the law expressly mentioned recognition by the father, the Court found no valid reason to deny the mother the same capacity, especially since the certainty of maternity is even greater than paternity. Recognition could be either express or tacit.

3. On the Sufficiency of Evidence: The Court held that the evidence offered by Rosa Llorentepertaining to the deceased mother’s acts of rearing, educating, authorizing baptism, and witness testimony of birthwas admissible to prove tacit or express recognition under the old law. The trial court erred in excluding this evidence based solely on the formal requirements of the new Civil Code.

Additional Principle: The Court further clarified that while the status of a natural child is determined by the law in force at the time of birth, the actual distribution of the inheritance is governed by the law in force at the time of the decedent’s death (in this case, Article 840 of the Civil Code).