G.R. No. L-12894; September 30, 1960
LILIA JUANA BARLES, MARIA ESTRELLA BARLES and REMEDIOS BARLES, plaintiffs and appellants, vs. DON ALFONSO PONCE ENRILE, defendant and appellee.

FACTS

On September 1, 1955, plaintiffs Lilia Juana Barles, Maria Estrella Barles, and Remedios Barles, all of legal age, filed a complaint in the Court of First Instance of Manila for “reconocimiento de filiacion paternal con dano moral.” They alleged they are the illegitimate (spurious) children of defendant Alfonso Ponce Enrile and their natural mother, Genoveva Barles, with whom the defendant cohabited at the time of their conception and birth. The defendant filed a motion to dismiss on grounds of failure to state a cause of action and prescription. The court deferred action on the motion. After the case was transferred to the newly organized Juvenile and Domestic Relations Court, it rendered a decision on June 1, 1957, dismissing the complaint. The lower court held that while the complaint, based on the evidence, stated a valid cause of action, the action had already prescribed. It ruled the cause of action accrued from birth and, applying the Code of Civil Procedure, found the complaint was not filed within the required periods. Plaintiffs appealed directly to the Supreme Court.

ISSUE

Whether the plaintiffs’ action for investigation of their spurious paternity under Article 289 of the new Civil Code has prescribed.

RULING

No. The Supreme Court reversed the lower court’s decision and remanded the case for further proceedings.
The Court held that the lower court misapplied the law. Plaintiffs’ action is authorized under Article 289 of the new Civil Code, which permits the investigation of the paternity of illegitimate (spurious) children under the circumstances specified in Articles 283 and 284. The new Civil Code does not specify a prescriptive period for this action. The Court ruled this action is similar to the action for compulsory recognition of natural children under Article 285, as both aim to prove filiation against a parent’s refusal, are based on the same grounds (Articles 283 and 284), and involve offspring of illicit relations. Therefore, by analogy and in the absence of an express contrary provision, the time limitation in Article 285 should apply. Article 285 allows the action to be brought during the lifetime of the presumed parents, with specific exceptions for filing after death. Since plaintiffs filed their action during the defendant’s lifetime, it was not barred by prescription.
The Court further clarified that while plaintiffs were born before the new Civil Code’s effectivity, Articles 283, 284, and 289 are expressly given retroactive effect under Article 2263(3). The cause of action did not accrue from birth; prescription runs from the time the action may be instituted. The old Civil Code did not permit such an investigation for spurious children, but the action is now authorized under the new Code.
In a subsequent Resolution dated January 28, 1961, the Court denied the defendant’s motion for reconsideration. It rejected the argument that the general five-year prescriptive period under Article 1149 should apply, reaffirming that Article 285 establishes a special prescriptive period grounded in public policy. It also cited the opinion in Zuzuarregui vs. Zuzuarregui to conclude that Article 285 limits not only actions for recognition by natural children but also actions for investigation of paternity by illegitimate children.