G.R. No. 86302 September 24, 1991
CASIMIRO MENDOZA, petitioner, vs. HON. COURT OF APPEALS and TEOPISTA TORING TUÑACAO, respondents.

FACTS

Private respondent Teopista Toring Tuñacao filed a complaint for compulsory recognition, alleging she was the illegitimate daughter of petitioner Casimiro Mendoza, who was married to another woman at the time of her conception. She claimed Mendoza recognized her through direct acts, including financial support, allowing her son to build a house on his land, and opening a joint bank account with her. Mendoza, then 91 years old, denied paternity and presented a counterclaim. The trial court dismissed the complaint, finding insufficient evidence of continuous possession of status as an illegitimate child.
The Court of Appeals reversed the trial court’s decision. It found that Teopista successfully proved her filiation through various acts and declarations of Mendoza. The appellate court gave weight to the testimonies of witnesses, including Mendoza’s relatives, who attested to his acknowledgment of Teopista as his child and his financial support for her and her mother. Mendoza appealed to the Supreme Court via certiorari.

ISSUE

Whether the Court of Appeals erred in reversing the trial court and in holding that Teopista Toring Tuñacao sufficiently proved her filiation as the illegitimate child of Casimiro Mendoza.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The legal logic centered on the application of Article 283 of the Civil Code, which governs compulsory recognition of illegitimate children. The Court emphasized that the provision must be liberally construed to allow the investigation of paternity. It found that Teopista presented competent evidence under Article 283(4), “any evidence or proof that the defendant is [her] father.”
This evidence included the testimonies of Mendoza’s relatives, Gaudencio and Isaac Mendoza, who recounted direct declarations and instructions from Casimiro Mendoza acknowledging Teopista as his daughter and providing her financial support. These verbal acts constituted admissions against interest. The Court also considered the corroborating circumstances: Mendoza hired Teopista’s husband, gave them proceeds from a truck sale, permitted her son to build on his land, and opened a joint bank account with her. Collectively, these acts demonstrated Mendoza’s treatment of Teopista as his child, fulfilling the standard of proof required for compulsory recognition. The trial court’s overly strict requirement of “continuous possession of status” was thus correctly overturned.