G.R. No. 1921
Facts Alejandra Siguiong filed a petition for partition of the estate of her deceased parents, Juan (Jose) Siguiong and Juana Tan‑Ayco, claiming she was their legitimate daughter. She alleged that she was born out‑of‑wedlock to Juan Siguiong and Maria Lerma (later Maria Du‑Yujo) and that Juan’s subsequent marriage to Maria in 1859 legitimated her. Her evidence consisted of baptismal certificates showing her named as the legitimate child of Juan Siguiong and testimonies of her mother and witnesses. The defendants, particularly Manuel Siguiong, denied her legitimacy and argued that she never secured any formal recognition of paternity during Juan’s lifetime.

Issue Whether Alejandra Siguiong may be considered a legitimated child of Juan (Jose) Siguiong, thereby acquiring a right to inherit from the intestate estate, based solely on (1) proof of her natural filiation, (2) the subsequent marriage of her father to her mother, and (3) the baptismal certificate that designated her as a legitimate child.

Ruling The Supreme Court affirmed the trial court’s decision. It held that a baptismal certificate alone does not prove paternal recognition, and under the applicable Spanish Civil Code provisions legitimation by subsequent marriage requires either (a) express or tacit recognition of the child by the father, or (b) a judicial declaration. Since the plaintiff failed to produce any such recognition and the evidence showed that Juan Siguiong never acknowledged her as his child, she could not be deemed legitimated. Consequently, her claim to an inheritance was dismissed and the judgment in favor of the defendant was affirmed, with costs awarded to the appellees.