G.R. No. L-9351; January 6, 1915
In the matter of the intestate of AUREA ENRIQUEZ and FRANCISCA REYES, deceased. VICENTE ATANASIO ENRIQUEZ and PEDRO GARCIA, petitioners-appellees, vs. RAFAEL AQUINO and JOSEFA AQUINO, respondents-appellants.

FACTS:
Francisca Reyes died intestate in 1898, survived by her two legitimate daughters, Petra Padilla and Pascuala Padilla. Petra had two legitimate children, Rafael and Josefa Aquino. Pascuala had a legitimate daughter, Aurea Enriquez. Petra, Pascuala, and Aurea have all since died. Rafael and Josefa Aquino claimed to be the sole heirs of both Francisca Reyes and Aurea Enriquez. Vicente Atanasio Enriquez, a minor, opposed this claim, asserting he was the natural child of Aurea Enriquez and thus entitled to inherit her separate property and her share in Francisca Reyes’s estate. The parties stipulated that Vicente was the son of Aurea Enriquez, begotten by a Roman Catholic priest. The lower court ruled in favor of Vicente, declaring him the owner of Aurea’s separate property and her share in Francisca’s estate. Rafael and Josefa Aquino appealed.

ISSUE:
Was Vicente Atanasio Enriquez a legally acknowledged natural child of Aurea Enriquez, thereby entitled to inherit from her intestate estate?

RULING:
Yes. The Supreme Court affirmed the lower court’s decision.
To be considered an acknowledged natural child under the Civil Code, two conditions must be met: (1) the child must be born out of wedlock to parents who, at the time of conception, could have legally married; and (2) the child must be legally acknowledged.
1. Capacity to Marry: The appellants argued that the priest-father’s holy orders constituted a canonical impediment to marriage, thus disqualifying Vicente as a natural child. The Court held that General Orders No. 68 (the Marriage Law), promulgated in 1899, governed. This law specified the only disqualifications and causes for nullity of marriage. The impediment of priesthood was not included. Therefore, under the law in force at the time of Vicente’s conception (1905), his parents could have legally married. The old canonical impediment was deemed revoked as repugnant to the new, inclusive law which separated church and state.
2. Acknowledgment: The stipulation of facts established that Vicente was the son of the unmarried Aurea Enriquez, fulfilling the requirement of acknowledgment.
3. Admissibility of Evidence on Parentage: The Court clarified that in an action contesting acknowledgment brought by prejudiced parties (like the appellants), it is essential and permissible to investigate the identity and marital capacity of both parents to determine if the child qualifies as a natural child. The stipulation regarding the father’s identity was therefore admissible. However, on the merits, this evidence showed the father was legally capable of marriage under General Orders No. 68.
Consequently, Vicente Atanasio Enriquez was a legally acknowledged natural child. Under Article 939 of the Civil Code, in the absence of legitimate descendants or ascendants, an acknowledged natural child succeeds to the entire estate of the deceased. Vicente was thus entitled to inherit all of Aurea Enriquez’s separate property and her undivided one-half share in the estate of Francisca Reyes.