GR L 6759; (February, 1912) (Digest)
G.R. No. L-6759, February 21, 1912
DEOGRACIAS SERRANO, petitioner-appellant, vs. ANDRES SERRANO ARAGON, opponent-appellee.
FACTS
Deogracias Serrano applied for the registration of two parcels of land (Parcel A and B) in Paco, Manila, originally owned by the spouses Maximo Serrano and Valentina Aragon, both deceased. Andres Aragon opposed, claiming he was a natural child of the spouses, legitimized by their subsequent marriage, and thus entitled to inherit half of Parcel A. He also asserted that Parcel B belonged to Deogracias and his sisters, Isidra and Maxima Serrano. The Court of Land Registration ruled in favor of Andres, ordering the registration of Parcel A in the names of Deogracias and Andres, and Parcel B in the names of Deogracias and Isidra. Deogracias appealed.
ISSUE
1. Whether Andres Aragon is a natural child of Maximo Serrano and Valentina Aragon, legitimized by their subsequent marriage, and thus entitled to inherit.
2. Whether Isidra Serrano sold all her interest in the land to Deogracias before the registration suit.
RULING
1. No, Andres Aragon failed to prove he is a legitimized natural child. The Court emphasized the strict requirements for establishing the status of a natural child under the Civil Code. Andresโs evidenceprimarily testimony from Isidra Serrano based on the familyโs use of the term “cuya” (which can also refer to a cousin or eldest brother) and lacking personal knowledge of his birthwas insufficient. His baptismal certificate identified him as the legitimate child of another couple (Teodorico Aragon and Lucia Vasquez). Public policy demands “clear, strong, and convincing” evidence to admit an illegitimate child into a legitimate family, especially after the parentsโ death. The action for acknowledgment generally dies with the parents (Art. 137, Civil Code), and no exception applied here.
2. Yes, Isidra Serrano sold all her interest to Deogracias. The Court found that a private document and testimonies from Deogracias and Maxima Serrano clearly established that Isidra sold her entire interest in the land to Deogracias before the suit.
The trial courtโs judgment was reversed. The Supreme Court ordered the registration of both parcels solely in the name of Deogracias Serrano, as prayed for in his petition.
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