G.R. No. L-10419; April 16, 1958
JULIO PAREJA, ET AL., petitioners-appellants, vs. PAZ PAREJA, ET AL., respondents-appellees.

FACTS

This case originated from a prior Supreme Court decision (G.R. No. L-5824) concerning the intestate estate of Natividad Pareja. In that case, Julio, Regina, Jose, and Soledad Pareja sought to be declared acknowledged natural children of the deceased. The Supreme Court found that an “Information for Membership Insurance” form signed by Natividad Pareja on March 12, 1939, designating them as his children/beneficiaries, constituted an “indubitable document” under Article 135 of the Spanish Civil Code. The Court reversed the lower court’s order but granted the appellees (the petitioners-appellants in the present case) the right to secure a declaration as recognized natural children under Article 137, paragraph 2, subject to a crucial condition: they must exercise this right within thirty days from the finality of the decision and must submit evidence that they had no knowledge of the existence of the said document more than six months prior to December 2, 1949. The present action was filed to comply with this grant. The petitioners alleged they came to know of the insurance application after Natividad’s death, in November 1949. The oppositors denied this, alleging the petitioners had knowledge of it and took no steps to secure acknowledgment during Natividad’s lifetime. The case was heard primarily on documentary evidence and an agreed fact stating the petitioners learned Natividad was insured after his death. The trial court found the petitioners failed to introduce evidence proving they lacked knowledge of the document for more than six months before December 2, 1949, and dismissed the petition.

ISSUE

Whether the petitioners-appellants complied with the condition set by the Supreme Court in its prior decision (G.R. No. L-5824) by submitting evidence that they had no knowledge of the existence of the indubitable document (the insurance application) for more than six months prior to December 2, 1949, as required under Article 137, paragraph 2 of the Spanish Civil Code to maintain their action for acknowledgment.

RULING

No. The Supreme Court affirmed the trial court’s decision dismissing the petition. The Court held that the finding of the trial court was not disputed on appeal: the petitioners failed to submit the required evidence to prove they lacked knowledge of the document’s existence for the critical period as mandated by the Court’s previous decision. The Court noted that counsel for the petitioners-appellants either failed to understand the import of the prior decision or made no attempt to comply with its specific condition. The Court reiterated its prior ruling that the insurance document, while an indubitable document under Article 135, was not the type of public document described in Article 131 that could by itself be the basis for an action for recognition; its use was specifically governed by the time limitation in Article 137, paragraph 2.