G.R. No. L-45736; May 26, 1939
In the matter of the Intestate Estate of the deceased Emeterio Lopez. CONCEPCION LOPEZ, petitioner-appellee, vs. ADELA LOPEZ, ET AL., oppositors-appellants.

FACTS

Emeterio Lopez died intestate without legitimate descendants, ascendants, or a widow. Concepcion Lopez filed a petition in the intestate proceedings, claiming to be an acknowledged natural daughter of the deceased and praying to be declared his universal heiress. The oppositors-appellants, nephews and nieces of the deceased, opposed the petition, denying her status and claiming the estate for themselves. After an amended petition was filed (as the estate’s value increased, requiring regular administration), an administrator was appointed. The administrator, through the same counsel representing the oppositors, filed a motion for a declaration of heirs, praying that the oppositors be so adjudged. After hearing, the lower court issued an order declaring Concepcion Lopez an acknowledged natural daughter of the deceased, entitled to inherit. The oppositors appealed, contending that Concepcion needed a separate action for recognition, that her petition was insufficient, and that they lacked notice of the hearing.

ISSUE

Whether Concepcion Lopez is an acknowledged natural daughter of Emeterio Lopez entitled to inherit his estate.

RULING

Yes. The Supreme Court affirmed the lower court’s order. The Court held that a person claiming to be an acknowledged natural child may intervene in the intestate proceedings to allege and prove such status, without the need for a separate action for recognition. The petition, while praying for declaration as universal heiress, sufficiently alleged in its body that she was a natural child in uninterrupted possession of that status; the prayer for relief is not part of the cause of action, and a pleader is entitled to relief as the facts warrant. The factual findings of the lower court—that Concepcion was born to Emeterio Lopez and Juana Cuison, who lived together as husband and wife until Juana’s death; that Emeterio maintained and treated Concepcion as his true daughter, calling her by nickname and being called “papa”; and that she lived with him until his death—constitute sufficient evidence of uninterrupted possession of the status of a natural child, warranting recognition. The claim of lack of notice by the oppositors was unsubstantiated; the presumption of regularity of proceedings stands, and their counsel (who also represented the administrator) filed the very motion asserting their right to succession, implying notice.