GR 157037; (May, 2004) (Digest)
G.R. No. 157037; May 20, 2004
ROSALINA P. ECETA, petitioner, vs. MA. THERESA VELL LAGURA ECETA, respondent.
FACTS
Petitioner Rosalina P. Eceta was married to Isaac Eceta, with whom she had a son, Vicente. During their marriage, they acquired a property in Cubao, Quezon City. Isaac died in 1967, leaving Rosalina and Vicente as his compulsory heirs. Vicente later died in 1977, survived by his mother, Rosalina, and his illegitimate daughter, respondent Maria Theresa Vell Lagura Eceta. In 1991, Maria Theresa filed an action for Partition and Accounting with Damages against Rosalina, claiming co-ownership of the Cubao property by virtue of her father Vicente’s death.
Rosalina defended by claiming the property was her paraphernal property. During pre-trial, the parties stipulated that Rosalina is Maria Theresa’s grandmother. The trial court ruled that Maria Theresa was entitled to a one-fourth share of the property. On appeal, the Court of Appeals modified this, reducing her share to one-eighth of the disputed property.
ISSUE
The core issue is whether Maria Theresa successfully proved her filiation to Vicente Eceta to establish her right to inherit from him and thus claim a share in the disputed property.
RULING
The Supreme Court denied Rosalina’s petition and affirmed the Court of Appeals. The Court clarified that the action was not one for compulsory recognition but for partition and accounting, and the issue of filiation was never genuinely in dispute. The parties had stipulated during pre-trial that Maria Theresa is Rosalina’s granddaughter, which was a judicial admission binding on Rosalina.
Furthermore, Maria Theresa successfully established her filiation by presenting her duly authenticated birth certificate, which was signed by Vicente Eceta himself. Under the Family Code, the filiation of illegitimate children is established by the record of birth appearing in the civil register. Vicente’s signature on the birth certificate constituted a consummated act of acknowledgment; it was a voluntary recognition in an authentic writing that requires no separate judicial action. Therefore, Maria Theresa’s status as Vicente’s illegitimate child and thus a compulsory heir was conclusively proven. Her rightful share in the inheritance from her father, which included a portion of the property in question, was correctly determined by the appellate court.