GR L 20946; (September, 1966) (Digest)
G.R. No. L-20946 September 23, 1966
EUGENIO C. DEL PRADO, plaintiff and appellant, vs. AUREA S. SANTOS, legal guardian of the minor JESUS SANTOS DEL PRADO, defendant and appellee.
FACTS
Eugenio C. del Prado filed a complaint to annul a deed executed by Aurea S. Santos adjudicating a parcel of land to the minor Jesus Santos del Prado, her son allegedly by plaintiff’s deceased brother, Anastacio C. del Prado. Plaintiff alleged deprivation of his rightful share in his brother’s estate. The parties stipulated the following facts: (1) Anastacio C. del Prado died intestate and single on August 11, 1958; (2) Plaintiff is a legitimate brother of the deceased; (3) Defendant Aurea S. Santos was legally married to another man but was factually separated; (4) The deceased and defendant cohabited without marriage, resulting in the birth of the minor Jesus S. del Prado on December 19, 1957, whom Anastacio admitted as his son in the latter’s birth certificate; (5) After Anastacio’s death, his estate, including a parcel of land, was adjudicated to the minor Jesus; and (6) The Register of Deeds cancelled the original title and issued a new one in the minor’s name.
ISSUE
Who has a better right to the parcel of land left by the late Anastacio C. del Prado, the plaintiff (legitimate brother) or the minor Jesus S. del Prado (alleged illegitimate son)?
RULING
The Supreme Court affirmed the lower court’s decision, ruling in favor of the minor Jesus S. del Prado. The Court held that based on the stipulated facts, the minor is the illegitimate son of the deceased, Anastacio C. del Prado, who admitted paternity in the birth certificate. Applying the New Civil Code (Article 2263), illegitimate children, under Article 287, have successional rights. Since the deceased died intestate without legitimate descendants or ascendants, his illegitimate child is entitled to succeed to his entire estate under Article 988, to the exclusion of the plaintiff who is only a collateral relative. The Court found appellant’s contention—that there was no valid recognition—untenable given the clear admission in the stipulated facts.