G.R. No. L-9665; February 29, 1916
In the matter of the settlement of the intestate estate of Ambrosio Rabalo, deceased. PETRONA REQUEJO, petitioner-appellee, vs. GABINA RABALO, respondent-appellant.

FACTS:
Petrona Requejo filed a petition for the settlement of the intestate estate of her deceased husband, Ambrosio Rabalo. She alleged that the deceased was survived by her (his widow) and their three children: Emilio, Eufrasia, and Gabina Rabalo. She further stated that Emilio later died without descendants. The petition prayed for the distribution of the estate accordingly. Gabina Rabalo opposed the petition, claiming she was the only legitimate child surviving her father. She contended that Emilio and Eufrasia were born before the marriage of Ambrosio and Petrona and that Ambrosio was not their father. The evidence established that Emilio and Eufrasia were indeed the children of Ambrosio Rabalo and Petrona Requejo born out of wedlock in 1871 and 1873, respectively. Ambrosio and Petrona were lawfully married on November 28, 1874, and their child Gabina was born in 1876. All three children were living at Ambrosio’s death, and Emilio died later without issue. From the date of the marriage in 1874 until Ambrosio’s death, Emilio and Eufrasia lived with him, were treated as his own children, and were openly given the status of acknowledged and legitimated children.

ISSUE:
Whether Emilio and Eufrasia Rabalo are entitled to inherit as legitimated children of Ambrosio Rabalo, despite the absence of a formal acknowledgment by public instrument or will as required under the Civil Code.

RULING:
Yes. The Supreme Court affirmed the lower court’s decree declaring Emilio and Eufrasia as acknowledged natural children legitimated by the subsequent marriage of their parents and entitled to corresponding heritable rights. The Court held that since the children were born and the parents were married over thirteen years before the Civil Code took effect in the Philippines, the applicable laws were the prior Spanish laws, specifically Law 11 of Toro and Law 1, Title 5, Book 10 of the Novisima Recopilacion. Under these old laws, no special form of acknowledgment was required. Recognition could be established by proof that the father had clearly signified his intention to recognize the children as his own and had given them the status of legitimated children. The evidence conclusively showed that Ambrosio Rabalo, from the time of his marriage in 1874 until his death, continuously recognized Emilio and Eufrasia as his children, treated them equally with his child born in wedlock (Gabina), and accorded them the full status of legitimated children. This long-continued public treatment and recognition were sufficient under the old laws to constitute acknowledgment and confer the status of legitimated natural children. The Court emphasized that this was not an action to compel recognition but a proceeding to determine rights of inheritance based on an already accomplished recognition during the father’s lifetime.