G.R. No. L-23060 June 30, 1967
Beatriz Paterno, et al., plaintiffs-appellants, vs. Jacoba T. Paterno, et al., defendants-appellees.

FACTS

The minors Beatriz and Bernardo Paterno, represented by their mother Feliza Orijuela, filed a complaint in the Juvenile and Domestic Relations Court (Civil Case No. 01124) against the surviving widow and legitimate children of the late Dr. Jose P. Paterno. They alleged they were illegitimate children of the deceased, conceived and born during his cohabitation with Orijuela, and were in continuous possession of the status of his children. They claimed that after the decedent’s death, the defendants executed an extrajudicial partition of his estate, depriving them of their rightful share. The complaint sought: (1) appointment of a guardian ad litem; (2) a declaration of their status as illegitimate (adulterous) children; (3) compulsory recognition as heirs; (4) nullification of the extrajudicial settlement; (5) determination and delivery of their hereditary share; (6) payment of actual, exemplary, and moral damages; and (7) support pendente lite. A previous complaint in the Court of First Instance of Manila (Civil Case No. 33467) had been dismissed for lack of jurisdiction as the principal question involved paternity. The Juvenile and Domestic Relations Court, after initially receiving evidence, later ordered the dismissal of the case for lack of jurisdiction, ruling that the main action was for recovery of a share in the estate, with paternity being merely incidental, and thus the ordinary courts should resolve all issues to avoid splitting causes of action.

ISSUE

Whether the Juvenile and Domestic Relations Court has jurisdiction over the case, specifically, to determine if the main cause of action is for recognition of paternity (which falls under its exclusive jurisdiction) or for participation in the estate and damages (which does not).

RULING

The Supreme Court set aside the order of dismissal insofar as it affected the issue of paternity and returned the case to the Juvenile and Domestic Relations Court for determination of that issue. The Court held that the plaintiffs’ main action was for compulsory recognition of their status as illegitimate children of the deceased, a matter within the exclusive original jurisdiction of the Juvenile and Domestic Relations Court under Section 38-A(b) of Republic Act 1401. Their right to share in the hereditary estate depended upon first establishing this filiation. The claim for participation in the estate and for damages, however, fell outside the special court’s jurisdiction. The Juvenile and Domestic Relations Court, being a court of special and limited jurisdiction, could not entertain these latter claims even under its “incidental powers,” as such powers refer only to authority necessary to carry out its functions over the subjects within its exclusive jurisdiction. This does not violate the rule against splitting a cause of action, as the bases for the claims (paternity vs. hereditary share/damages) are not the same and, due to the creation of the special court, these claims now lie within the jurisdiction of different tribunals.