G.R. No. L-18882; November 29, 1963
CLAUDIA MEJIA, FELICIANO MEJIA, NARCISA MEJIA, FELIPE MEJIA, JULITA MEJIA and ALFREDO MEJIA, plaintiffs-appellants, vs. CASILDA M. DE MEJIA, defendant-appellee.

FACTS

The plaintiffs, alleging to be the voluntarily recognized illegitimate children of the late Teofilo Mejia who died in 1942, filed an action for partition and accounting against his widow, Casilda M. de Mejia. They sought a share in eight parcels of land they claimed belonged to the conjugal partnership of the spouses. The defendant denied the recognition and ownership of the properties, asserting defenses including prescription and that the lands belonged to a corporation.
After requiring memoranda on the issues, the trial court dismissed the complaint. It ruled that under the Spanish Civil Code in force at the time of Teofilo’s death, adulterous children (which the plaintiffs appeared to be) had only a right to support, not successional rights. The court held that the successional rights granted to such children under the new Civil Code of the Philippines could not be applied retroactively to impair vested rights acquired at the time of death.

ISSUE

Whether the plaintiffs, as alleged adulterous children, can claim successional rights under the Civil Code of the Philippines despite their alleged father having died in 1942 when the Spanish Civil Code was in force.

RULING

No. The Supreme Court affirmed that the plaintiffs have no successional rights to the estate of Teofilo Mejia. The legal logic is grounded in the non-retroactivity of laws concerning vested rights. When Teofilo died in 1942, the governing law was the Spanish Civil Code, under which his heirs acquired immediate and vested rights to his estate. Adulterous children had no successional rights under that code, being entitled only to support.
Article 2263 of the new Civil Code explicitly provides that rights to the inheritance of a person who died before its effectivity shall be governed by the Civil Code of 1889 (the Spanish Civil Code). While Article 2264 grants the new successional rights to children born before the Code’s effectivity, this is qualified by Article 2253, which states that a newly declared right cannot prejudice or impair any vested or acquired right. Applying the new successional rights to this case would impair the vested rights of the heirs recognized in 1942. Therefore, the trial court correctly held the complaint insufficient for partition.
However, the Supreme Court reversed the outright dismissal. The complaint alleged that some plaintiffs were minors. Under Article 845 of the Spanish Civil Code, the obligation to support illegitimate children without natural status was transmitted to the heirs of the obligor and continued until the children reached majority. Thus, assuming the allegations as hypothetically true, any plaintiffs who were minors in 1942 potentially had a cause of action for support against the estate’s heirs, including the defendant widow. The case was remanded for further proceedings solely on that limited issue of support.