G.R. No. L-11483-11484; February 14, 1958
In the matter of the Testate Estate of the deceased Edward E. Christensen, ADOLFO CRUZ AZNAR, petitioner. MARIA LUCY CHRISTENSEN DANEY and ADOLFO CRUZ AZNAR, petitioners-appellants, vs. MARIA HELEN CHRISTENSEN GARCIA and BERNARDA CAMPOREDONDO, oppositors-appellees. BERNARDA CAMPOREDONDO, plaintiff-appellee, vs. ADOLFO CRUZ AZNAR, as Executor of the Deceased EDWARD E. CHRISTENSEN, defendant-appellant.

FACTS

Edward E. Christensen, an American citizen, died on April 30, 1953, leaving a considerable estate. He had a will naming Adolfo Cruz Aznar as executor. The will declared he had only one child, Maria Lucy Christensen Daney, and made her the principal beneficiary. It also provided a legacy of P3,600 to Maria Helen Christensen Garcia (stating she was not related to him) and P1,000 to Bernarda Camporedondo. Bernarda Camporedondo had lived with Christensen as husband and wife for over 30 years, and two children, Lucy and Helen, were allegedly born from this relationship. Oppositions to the probate of the will were filed. Maria Helen Christensen Garcia contested the will, claiming she was a child of the deceased and the dispositions were illegal. Bernarda Camporedondo also opposed, claiming ownership over one-half of the estate by co-ownership due to their long-term cohabitation. Her opposition was dismissed in the probate proceeding, prompting her to file a separate civil case (G.R. No. L-11483) to establish her claim. The lower court allowed the will and found that Maria Helen Christensen Garcia had been in continuous possession of the status of a natural child of the deceased. It directed Maria Lucy Christensen Daney to acknowledge Helen as a natural child. Lucy and the executor appealed this portion of the decision.

ISSUE

The principal issue is whether the lower court erred in finding that oppositor Maria Helen Christensen Garcia had been in continuous possession of the status of a natural child of the deceased Edward E. Christensen. The related issue in the separate civil case is whether Bernarda Camporedondo, as a common-law wife, has a right to one-half of the estate acquired during their cohabitation.

RULING

The Supreme Court affirmed the decision in G.R. No. L-11484 with modification. It held that the lower court correctly found Maria Helen Christensen Garcia to be in continuous possession of the status of a natural child of the deceased, based on the facts presented. However, the Court modified the decision by stating that Maria Lucy Christensen Daney need not be compelled to acknowledge Helen; the court’s declaration of Helen’s status is sufficient for her to claim the rights inherent to being an acknowledged natural child. Regarding the claim of Bernarda Camporedondo in G.R. No. L-11483, the Supreme Court reversed the lower court’s decision. It ruled that the New Civil Code, which introduced the system of absolute community of property, could not be applied retroactively to impair the vested rights of the deceased’s compulsory heirs. Since the properties were acquired under the old Civil Code and the relationship was not a legal marriage, no co-ownership existed. Therefore, her complaint was dismissed. Costs were taxed against appellants in G.R. No. L-11484 and against appellee Bernarda Camporedondo in G.R. No. L-11483.