G.R. No. L-24414 July 31, 1968
DIONICIA J. CID, AMADOR JULIAN, ESCOLASTICA J. AGCAOILI, DOMINGA J. SALMO and TEODORO JULIAN, petitioners, vs. NANCY W. BURNAMAN, ELIS J. BURNAMAN, and the COURT OF APPEALS, respondents.

FACTS

Urban Lot No. 9008 was originally decreed in undivided halves, one half to Gregoria Bonoan and the other half to the five petitioners (the Julians). Upon Gregoria’s death in 1938, her son Cenon Bonoan (also known as Cenon Hernando) possessed her Certificate of Title. In 1950, Cenon executed an affidavit adjudicating to himself Gregoria’s entire half-interest as her “only legal heir,” which was annotated on the title. That same day, the Julians executed a special power of attorney in favor of Cenon to mortgage their share. In 1956, Cenon executed two deeds of sale to respondent Nancy Burnaman: first for a one-fourth interest (unrecorded), and later for an undivided half-interest, stating he was the “absolute owner” of that half. This second deed was recorded, and a new title was issued showing Nancy as owner of one half and the Julians as owners of the other half. The petitioners (Julians) filed a complaint seeking to annul Cenon’s sale of a one-fourth interest, claiming that upon Gregoria’s death, her half-interest should have been inherited equally by her two children, Cenon and Engracia (the petitioners’ mother). Therefore, the petitioners claimed an additional one-fourth interest through their mother, making them owners of three-fourths total. They alleged the Burnamans were purchasers in bad faith. The Court of First Instance ruled in favor of the petitioners. The Court of Appeals reversed, finding that Engracia was an illegitimate child of Gregoria who was never acknowledged, either voluntarily or compulsorily. It held that her baptismal certificate did not constitute a valid act of acknowledgment. Consequently, Engracia could not inherit from Gregoria, and her children (the petitioners) acquired no successional rights to Gregoria’s estate through her. The appellate court also found the Burnamans to be purchasers in good faith.

ISSUE

Whether the Court of Appeals erred in dismissing the petitioners’ complaint, specifically by inquiring into and ruling upon the heirship status of Engracia (the petitioners’ mother) in an ordinary civil action.

RULING

The Supreme Court affirmed the decision of the Court of Appeals. The Court held that the appellate court’s inquiry into Engracia’s filiation and status was proper because the petitioners, as claimants to an additional proprietary interest, had the burden to prove the strength of their own title, which was based on hereditary succession from Gregoria Bonoan through their mother. To succeed as an heir under the Civil Code of 1889 (applicable at Gregoria’s death), an illegitimate child needed to be acknowledged. The Court agreed with the Court of Appeals that Engracia’s baptismal certificate was not a valid act of acknowledgment, as such an act must be executed by the parent, not a parish priest. Since Engracia was not acknowledged, she could not inherit from Gregoria and could not transmit any successional rights to her children, the petitioners. Therefore, the petitioners failed to establish a cause of action for the additional one-fourth share. The Court further noted that the issue of the Burnamans’ good or bad faith was irrelevant absent a showing that the petitioners were entitled to the ownership they claimed. The action of the Court of Appeals was not a declaration of heirship but a necessary testing of the chain of title relied upon by the petitioners.