G.R. No. 112229 March 18, 1997
RAYMOND PE LIM, petitioner, vs. COURT OF APPEALS, JOANNA ROSE C. PE LIM, Minor represented by her Natural Mother and Guardian, MARIBEL CRUZ y TAYAG, respondents.

FACTS

Maribel Cruz filed a complaint for child support against Raymond Pe Lim on behalf of her minor daughter, Joanna Rose C. Pe Lim. Maribel alleged that in 1978, she and Raymond began a romantic relationship, cohabited in various apartments paid for by him, and conceived Joanna Rose. She left for Japan pregnant in 1981 and gave birth upon her return. Raymond paid her hospital bills and caused the child to be registered under the surname “Pe Lim.” Their relationship continued until he abandoned them in 1983. Raymond denied paternity, claiming he and Maribel were merely friends who met at a club where she worked. He admitted giving her financial assistance and paying for the apartment and hospital bills out of pity when she returned from Japan pregnant, but insisted he was not the father, suggesting she conceived while abroad.

ISSUE

Whether the petitioner, Raymond Pe Lim, is legally the father of the minor Joanna Rose C. Pe Lim and thus obligated to provide support.

RULING

The Supreme Court affirmed the lower courts’ rulings, holding that Raymond Pe Lim is the father of Joanna Rose and is obligated to provide support. The legal logic centers on the establishment of illegitimate filiation under the Family Code. Article 175 provides that such filiation may be established in the same manner as for legitimate children. Per Article 172, filiation can be proven by a record of birth, an admission in a public document or private handwritten instrument signed by the parent, open and continuous possession of status, or any other means allowed by the Rules of Court. The Court found that the totality of evidence overwhelmingly established paternity. This evidence included Raymond’s handwritten love letters to Maribel referring to Joanna Rose as their child and expressing his paternal role, his payment of hospital bills, his procurement of the child’s birth certificate bearing his surname, and photographs of him cuddling the infant. His open acknowledgment and conduct prior to his separation from Maribel constituted a clear admission of paternity. His subsequent denial, after he married another woman, was deemed a belated and unconvincing attempt to evade responsibility, which could not outweigh the consistent and corroborative evidence of his earlier recognition. Consequently, his obligation to provide monthly support was upheld.