G.R. No. 108366 February 16, 1994
JOHN PAUL E. FERNANDEZ, ET AL., petitioners, vs. THE COURT OF APPEALS and CARLITO S. FERNANDEZ, respondents.

FACTS

Petitioners John Paul E. Fernandez and Claro Antonio Fernandez, through their mother Violeta P. Esguerra, filed an action for recognition and support against private respondent Carlito S. Fernandez. Violeta claimed she met Carlito in 1983, had an illicit relationship resulting in the births of Claro Antonio on March 1, 1984, and John Paul on an unspecified date, and that they underwent a civil marriage in October 1983 using a spurious license. Petitioners presented as evidence their birth certificates and Claro Antonio’s baptismal certificate naming Carlito as father, photographs from Claro’s baptism and of Carlito with the child at Violeta’s home, and testimonies from witnesses (Rosario Cantoria, Dr. Milagros Villanueva, Ruby Chua Cu, and Fr. Liberato Fernandez) who stated Violeta introduced Carlito as her “husband” or that Carlito presented himself as the father during the baptism. Carlito denied paternity, claiming he was merely a baptismal sponsor, a fact corroborated by his officemate Rodante Pagtakhan. He also presented a waiter, Fidel Arcagua, who disputed Violeta’s claim that they frequented a restaurant together. The Regional Trial Court ruled in favor of the petitioners, ordering recognition and support. The Court of Appeals reversed the decision, dismissing the complaint on grounds of insufficient evidence to prove paternity and applying the doctrine of res judicata due to a prior dismissed case for support (Civil Case No. Q-45567) where the court found no sufficient evidence of filiation.

ISSUE

Whether the Court of Appeals erred in finding that the evidence presented by the petitioners was insufficient to prove the paternity and filiation of the petitioners to the private respondent.

RULING

The Supreme Court dismissed the petition and affirmed the Decision of the Court of Appeals. The Court held that the evidence presented by the petitioners was inadequate to prove paternity and filiation. Specifically: (1) The photographs from the baptism and of Carlito with the child were insufficient proof of paternity, as they could merely show his presence as a sponsor or affection, not fatherhood. (2) The baptismal certificate, while a public document, is only evidence of the administration of the sacrament, not competent evidence of the veracity of entries regarding paternity, especially absent proof of Carlito’s participation in its preparation. (3) The certificates of live birth are incompetent evidence of paternity because they were not signed by the alleged father (Carlito) and were prepared without his intervention, violating the prohibition against recording an illegitimate child’s paternity based on a third person’s information. (4) The testimony of Fr. Liberato Fernandez was undermined by his admission on cross-examination that he had to be shown a picture by Violeta to recognize Carlito, casting doubt on his independent recollection. (5) The testimony of Violeta Esguerra was self-serving and, by itself, insufficient to prove paternity. The Court found no reason to disturb the appellate court’s factual findings and credibility assessments. The Court deemed it unnecessary to rule on the applicability of res judicata given its finding on the insufficiency of the evidence.