G.R. No. 50974 -75 May 31, 1989
JUAN CASTRO and FELICIANA CASTRO, petitioners, vs. HON. COURT OF APPEALS, CIPRIANO NAVAL and BENITA C. NAVAL, respondents.

FACTS

Petitioners Juan Castro and Feliciana Castro, siblings of the late Eustaquio Castro, and Marcelina Bautista, Eustaquio’s surviving spouse, filed separate complaints for partition of properties against respondent Benita Castro Naval. They later amended these to actions to quiet title, contesting Benita’s status as an heir. Benita claimed to be the acknowledged illegitimate child of Eustaquio Castro with Pricola Maregmen. The parties stipulated that the central issue was whether Benita was indeed the acknowledged natural child of Eustaquio.
The evidence established that Benita was born on March 27, 1919. Eustaquio Castro registered her birth, stating he was the father. Her baptismal certificate also named Eustaquio and Pricola as parents. After Pricola’s death, Eustaquio cared for Benita, supported her education, and gave her away at her wedding to Cipriano Naval. Benita and her husband lived with Eustaquio until his death. Family photographs from his wake included Benita among the immediate mourners.

ISSUE

Whether Benita Castro Naval was a duly acknowledged illegitimate child of Eustaquio Castro, entitled to inherit from his estate.

RULING

Yes. The Supreme Court affirmed the decisions of the lower courts recognizing Benita as Eustaquio’s acknowledged illegitimate child. The legal logic proceeds from the evidence of continuous possession of status and the retroactive application of the Family Code. Under the Civil Code in force at Eustaquio’s death, acknowledgment could be voluntary or compulsory. The Court found ample evidence of voluntary acknowledgment through Eustaquio’s consistent acts: registering himself as the father on the birth certificate, assuming parental care, providing financial support, integrating Benita into the family, and giving her away at her wedding. These acts constituted a clear and continuous recognition of filiation.
Crucially, the Court applied the Family Code retroactively, as no vested rights were impaired. The Code simplifies filiation into legitimate and illegitimate categories and allows illegitimate children to prove filiation by the same evidence as legitimate children. Article 172 permits proof by the “open and continuous possession of the status.” The record unequivocally shows Benita enjoyed this status as Eustaquio’s child throughout his life. Her defense of this status in the lawsuit was equivalent to the lifetime action to claim filiation permitted by law. Therefore, her hereditary rights were firmly established, warranting dismissal of the petition to exclude her from the inheritance.