G.R. No. L-15055. July 21, 1961.
CONSOLACION ROSETE, CHARITO ROSETE, MARY LO ROSETE, and ELIZABETH ROSETE, all minors, assisted by their Mother EUGENIA CARAG, as guardian ad litem, plaintiffs-appellees, vs. PABLO ROSETE, defendant-appellant.

FACTS

The minor plaintiffs, assisted by their mother Eugenia Carag, filed a complaint in the Juvenile and Domestic Relations Court against Pablo Rosete, seeking judicial recognition as his illegitimate children. The complaint alleged that Rosete, though legally married to another, courted Carag with a promise of marriage, cohabited with her, and fathered the plaintiffs during that period. While acknowledging some support had been given, they claimed it was insufficient and sought to establish filiation to legally claim support. In his amended answer, Rosete categorically denied any relationship with Carag, asserting she had cohabited with other men and that the children were not his. He claimed never to have supported or recognized them and, by way of counterclaim, sought damages for the allegedly malicious suit.
After trial, the lower court rendered judgment in favor of the plaintiffs. The court discredited the evidence presented by the defense and gave credence to the testimony of Eugenia Carag. Applying Articles 283 and 289 of the Civil Code, the court compelled Rosete to recognize the minors as his illegitimate children and ordered him to pay attorney’s fees and costs.

ISSUE

Whether the Supreme Court has jurisdiction over the direct appeal filed by the defendant, which primarily raises questions of fact and non-substantial constitutional issues.

RULING

The Supreme Court ruled that it did not have appellate jurisdiction and ordered the case certified to the Court of Appeals. The legal logic hinges on the proper allocation of appellate jurisdiction between the Supreme Court and the Court of Appeals based on the nature of the questions raised. The Court examined the grounds of appeal as stated in the appellant’s brief. These grounds largely challenged the trial court’s assessment of the credibility of witnesses, the weight given to testimonial evidence, and the factual conclusions drawn therefrom—all quintessential questions of fact. The appellant’s ancillary claim regarding a denial of a fair trial and a violation of the right against self-incrimination, stemming from being compelled to write during trial, was found not to present a substantial constitutional question that would vest jurisdiction in the Supreme Court.
The Court based its decision on applicable procedural statutes. Section 38-E of Republic Act No. 409 (the Manila Charter), as amended, provides that appeals from the Juvenile and Domestic Relations Court follow the same procedure as appeals from Courts of First Instance. Furthermore, Section 2 of Republic Act No. 2613 , which amended the Judiciary Act, grants the Court of Appeals jurisdiction over appeals involving questions of fact. Since the appeal was fundamentally anchored on factual issues, the Supreme Court held that jurisdiction properly lay with the Court of Appeals for a determination on the merits. The certification of the case was therefore a procedural necessity to ensure the appeal was heard by the correct appellate tribunal.