G.R. No. 180284 September 11, 2013
NARCISO SALAS, Petitioner vs. ANNABELLE MATUSALEM, Respondent

FACTS

Annabelle Matusalem filed a complaint for support against Narciso Salas, claiming he fathered her child, Christian Paulo, born in December 1994. She alleged that Salas, portraying himself as a widower, initiated a relationship, provided financial support during her pregnancy, rented an apartment for her, and paid all hospital expenses for the child’s delivery. After the birth, Salas’s family offered to adopt the child and provide her money to go abroad. Upon her refusal, Salas allegedly ceased all support. Salas denied paternity, asserting his assistance was purely altruistic and that Matusalem was a woman of loose morals attempting to extort him. The trial court, after Salas waived his right to present evidence, ruled in favor of Matusalem, ordering monthly child support. The Court of Appeals affirmed this decision.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s finding that Salas is the putative father of Christian Paulo and is thus obligated to provide support.

RULING

The Supreme Court denied the petition and affirmed the lower courts’ decisions. The legal logic centers on the establishment of filiation for purposes of support under Article 195 of the Family Code. In an action for support, filiation can be proven by any credible means. The Court found that Matusalem presented sufficient evidence to establish Salas’s paternity through his voluntary recognition and continuous acts of acknowledgment. His conduct—providing sustained financial assistance during pregnancy and after birth, securing her housing, personally attending to her during delivery, expressing joy over having a “look-alike” son, and initially providing for them—collectively constituted clear recognition of the child. These acts are competent evidence under Article 172 of the Family Code. The Court emphasized that for support obligations, the standard of proof is not as stringent as in other paternity cases; only credible evidence is required. Salas’s failure to rebut this evidence, due to his waiver of the right to present counter-evidence, left Matusalem’s testimony and that of her witness uncontroverted. Consequently, the factual findings of the lower courts, which are generally binding, sufficiently established the filiation necessary to compel Salas to provide support for his illegitimate child.