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7 Wills, Sole Heir Hilario V Miranda, Nov 28, 2018 DIGEST Edited

The Supreme Court of the Philippines ruled in favor of the petitioner in a case regarding proof of filiation and inheritance rights. The Court held that a prior final judgment of the Regional Trial Court declaring Magdalena as the illegitimate daughter of Antonio established her filiation. Under Philippine law, a final judgment can prove filiation. As the RTC's findings were based on evidence presented, there was no need to disturb its ruling. The final judgment constituted res judicata and could not be overturned by the Court of Appeals in a subsequent case involving inheritance from Antonio and Dolores.

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1K views2 pages

7 Wills, Sole Heir Hilario V Miranda, Nov 28, 2018 DIGEST Edited

The Supreme Court of the Philippines ruled in favor of the petitioner in a case regarding proof of filiation and inheritance rights. The Court held that a prior final judgment of the Regional Trial Court declaring Magdalena as the illegitimate daughter of Antonio established her filiation. Under Philippine law, a final judgment can prove filiation. As the RTC's findings were based on evidence presented, there was no need to disturb its ruling. The final judgment constituted res judicata and could not be overturned by the Court of Appeals in a subsequent case involving inheritance from Antonio and Dolores.

Uploaded by

Ariane Espina
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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*** TOPIC: PATERNITY AND FILIATION: PROOF OF FILIATION: Final judgment

declaring filiation [XIII F, 1. b. ]

[G.R. No. 196499. November 28, 2018.]


INGRID V. HILARIO, petitioner, vs. THELMA V. MIRANDA and IRENEA BELLOC, respondents.

J. JARDELEZA, FIRST DIVISION

Nature of the Action: petition for review on certiorari

FACTS:

On May 31, 2000 [Civil case No. AV-929], the Regional Trial Court declared in its decision
the following pertinent conclusions:

a) That Antonio Belloc died single, survived by his two illegitimate children, plaintiff
Magdalena Varian, Dolores Retiza and his grandson Teresito Flamor. Accordingly, he died
intestate and his intestate estate will pass on and will be inherited by his intestate heirs upon
his death; and

b) That evidence disclosed further that at the time of Dolores Retiza’s death sometime
in 1995, being without issue, her only surviving heir is her half-sister, the plaintiff Magdalena
and her nephew, Teresito Flamor who, under the law on intestate succession will be the ones
entitled to inherit her properties.

This decision became final on May 12, 2001.

On July 2, 2001, Petitioner Ingrid V. Hilario (Ingrid) filed two petitions for the issuance of
letters of administration with urgent application for appointment of a special administratrix,
both dated June 22, 2001, involving the properties of Antonio and Dolores, respectively. She
alleged that she is the daughter of Magdalena Varian (Magdalena).

On June 9, 2003, Magdalena died

On August 25, 2004, Irenea filed a motion for leave to intervene and opposition-in-
intervention. She claimed that she is the niece both of Antonio on the father side and Silveria
on the mother side of Dolores, and the latter was her first cousin. She claimed that Magdalena
cannot inherit from Dolores because she (Magdalena) is not a daughter of Antonio. Irenea also
alleged that since she is the nearest surviving relative of both Antonio and Dolores, she is
entitled to be appointed as sole administrator of their estate.

The RTC, finding that Irenea’s claims were unsubstantiated, ruled in favour of Ingrid,
declaring that Magdalena had established sufficient proof to be declared an heir of Antonio as
his illegitimate daughter, and an heir of Dolores, as her half sister.

On Appeal to the Court of Appeals, reversed and set aside said ruling. It held that
although Magdalena was Antonio's spurious daughter, she nevertheless cannot inherit from his
estate because she was not recognized by him either voluntarily or by court action. That her
right to inherit depends upon the acknowledgment or recognition of her continuous enjoyment
and possession of the status of child of her supposed father.
ISSUE:

Whether or not Magdalena’s filiation as Anotnio’s illegitimate child has been established
by the final judgment rendered by the RTC.

RULING:

The Supreme Court granted the petition and reversed and set aside the decision of the
Court of Appeals. It held that:

The Court is compelled to rule in favor of petitioner on the basis of the final judgment
rendered by the RTC in Civil Case No. AV-929 which established Magdalena's filiation. Under
paragraph 1, Article 172 of the Family Code, "final judgment" is a means of establishing filiation.
It refers to a decision of a competent court finding the child legitimate or illegitimate. We find
no need to disturb the RTC's findings which are based on the evidence presented for its
consideration in the course of the proceeding. While the subject of Civil Case No. AV-929 is the
declaration of nullity of certain documents, the ruling on Magdalena's filiation cannot be
considered obiter dictum since the RTC determinedly discussed and settled that issue as a
means to decide the main issue brought for its disposition. Being a final judgment, the Decision
in Civil Case No. AV-929 constitutes res judicata.

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