G.R. No. L-3299; August 29, 1951
Martina Ramos, et al., plaintiffs-appellants, vs. Caridad Ortuzar, et al., defendants-appellants.
FACTS
Percy A. Hill, an American, cohabited with Martina Ramos from 1905 to 1914 and begot six children, including Richard Hill and Marvin Hill. In 1914, Hill canonically married Helen Livingstone, with whom he had three children. After Livingstone’s death, Hill married Caridad Ortuzar in 1924, with whom he had one daughter. Upon Hill’s death in 1937, his estate was settled, and Caridad Ortuzar was appointed administratrix. The estate was partitioned among Hill’s children by Livingstone and Ortuzar, and later, the heirs sold six tracts of land to Maximo Bustos. Martina Ramos, claiming to be Hill’s lawful wife, and her sons Richard and Marvin Hill, claiming to be legitimate children, filed an action to annul the judicial partition and the subsequent sale to Bustos. The trial court found that Martina Ramos was not legally married to Hill, but that Richard and Marvin Hill were his acknowledged natural children. It declared Bustos’s purchase null and void, allotted portions of the estate to Richard and Marvin Hill along with Hill’s other children, and awarded damages to the plaintiffs. Both parties appealed.
ISSUE
1. Whether Martina Ramos was legally married to Percy A. Hill.
2. Whether Richard Hill and Marvin Hill were acknowledged natural children of Percy A. Hill.
3. Whether the action for acknowledgment was barred.
4. Whether Martina Ramos had a claim to the properties acquired by Hill.
RULING
1. No, Martina Ramos was not legally married to Percy A. Hill. The Supreme Court affirmed the trial court’s finding, noting the absence of a marriage certificate or registry entry, and cited additional circumstances refuting the marriage, such as Ramos’s subsequent cohabitation with Teodoro Tobias, documentary evidence describing her as Tobias’s wife, her failure to claim a share in Hill’s estate proceedings, and the improbability of Hill publicly marrying twice while his alleged first wife was alive and residing nearby.
2. The Supreme Court reversed the trial court’s finding that Richard Hill and Marvin Hill were acknowledged natural children. The Court held that the requirements for voluntary acknowledgment under Article 131 of the Spanish Civil Code were not met, as an acknowledgment in a birth record is not recognized in the Philippines. For compulsory acknowledgment under Article 135, the action was barred by Hill’s death, as Article 137 allows such an action only during the lifetime of the parents, with an exception for minors, which did not apply since Richard and Marvin Hill were of age when their father died.
3. Yes, the action for acknowledgment was barred by Percy A. Hill’s death, as provided under Article 137 of the Spanish Civil Code.
4. No, Martina Ramos had no claim to the properties acquired by Hill. The evidence did not sustain her contention of co-ownership or partnership in the acquisition of the properties, which were registered in Hill’s or Livingstone’s name between 1916 and 1930. Any right she might have had was lost by prescription, as Hill and Livingstone possessed the properties adversely, exclusively, and publicly since 1914, and Ramos failed to assert any claim for over 30 years.
The appealed decision was affirmed insofar as it declared no legal marriage between Martina Ramos and Percy A. Hill, but reversed in all other respects. Costs were awarded against the plaintiffs.
