G.R. No. 197099 September 28, 2015
EUGENIO SAN JUAN GERONIMO, Petitioner, vs. KAREN SANTOS, Respondent.

FACTS

Petitioner Eugenio San Juan Geronimo and his brother Emiliano (later deleted as co-petitioner) executed a document titled “Pagmamana sa Labas ng Hukuman” declaring themselves as the only heirs of the deceased spouses Rufino and Caridad Geronimo and adjudicating to themselves a 6,542-square meter property. Respondent Karen Santos, claiming to be the only child and sole heir of the spouses, filed a complaint for annulment of said document and recovery of possession. She alleged the property passed to her by intestacy. Petitioner denied respondent was the legitimate child, asserting the spouses were childless and respondent was merely a ward, the child of Caridad’s sister. He challenged the authenticity of respondent’s birth certificate, noting erasures on the date of birth and the informant’s signature, and presented evidence that Caridad, a teacher, never filed for maternity leave. Respondent testified she was the legitimate child, presented her birth certificate, and cited acts of recognition such as being sent to school by the spouses, being a beneficiary of Caridad’s burial benefits, and a guardianship petition filed by Caridad after Rufino’s death. The Regional Trial Court (RTC) ruled in favor of respondent, declaring the extrajudicial settlement null and void, annulling the tax declaration in petitioner’s name, and ordering petitioner to vacate and surrender possession. The Court of Appeals (CA) affirmed the RTC decision. The CA, however, found the birth certificate questionable as the informant, Emma Daño, was not identified as a parent, physician, or midwife, and held that the guardianship order was not a final judgment proving filiation.

ISSUE

Whether the filiation of respondent Karen Santos as the legitimate child of the spouses Rufino and Caridad Geronimo was sufficiently proven to establish her right to inherit the subject property, thereby rendering the “Pagmamana sa Labas ng Hukuman” executed by petitioner null and void.

RULING

The Supreme Court REVERSED and SET ASIDE the assailed Decision and Resolution of the Court of Appeals and DISMISSED the Complaint for Annulment of Document and Recovery of Possession. The Court held that respondent failed to prove her legitimate filiation. A birth certificate is a prima facie evidence of filiation only if it complies with the requirements of Act No. 3753 , meaning it must be signed by the attending physician/midwife or, in default, by either parent. The birth certificate (Exhibit 14) was signed by an unidentified informant, Emma Daño, and contained alterations; thus, it did not qualify as the valid registration of birth envisioned by law. The secondary evidence under Article 172 of the Family Code—the open and continuous possession of the status of a legitimate child—was not sufficiently established. The cited acts (being sent to school, being a beneficiary, the guardianship petition) were equivocal and could be consistent with treating respondent as an adopted child or ward, not necessarily as a legitimate child. The guardianship order was not a final judgment declaring legitimacy. Since filiation was not duly proven, respondent had no legal right to inherit from the spouses. Consequently, petitioner, as a brother of the deceased Rufino, is a legal heir under the rules of intestate succession. The “Pagmamana sa Labas ng Hukuman,” while an extrajudicial settlement among heirs, was not intrinsically void, and its validity or invalidity does not affect petitioner’s right as an heir. The action for annulment of document and recovery of possession was premised on respondent’s status as sole heir, which she failed to establish.