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    ARTICLE 175 - Narciso Salas Vs Annabelle Matusalem

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    This case involved a petition filed by Narciso Salas challenging a lower court ruling that he was the father of Annabelle Matusalem's child, Christian Paulo Salas, and thus obligated to pay child support. The Supreme Court ruled that: 1) Matusalem did not sufficiently establish the illegitimate filiation of the child under the Family Code, as the evidence presented, such as hospital bills and photographs, were not signed by Salas; 2) A birth certificate alone is not competent evidence of paternity if the putative father did not sign it; and 3) Baptismal certificates only prove the administration of sacraments, not paternity. The Supreme Court reversed the lower courts and

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    ARTICLE 175 - Narciso Salas Vs Annabelle Matusalem

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    saminah
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    This case involved a petition filed by Narciso Salas challenging a lower court ruling that he was the father of Annabelle Matusalem's child, Christian Paulo Salas, and thus obligated to pay child support. The Supreme Court ruled that: 1) Matusalem did not sufficiently establish the illegitimate filiation of the child under the Family Code, as the evidence presented, such as hospital bills and photographs, were not signed by Salas; 2) A birth certificate alone is not competent evidence of paternity if the putative father did not sign it; and 3) Baptismal certificates only prove the administration of sacraments, not paternity. The Supreme Court reversed the lower courts and

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    ARTICLE 175_Narciso Salas vs Annabelle Matusalem

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    This case involved a petition filed by Narciso Salas challenging a lower court ruling that he was the father of Annabelle Matusalem's child, Christian Paulo Salas, and thus obligated to pay child support. The Supreme Court ruled that: 1) Matusalem did not sufficiently establish the illegitimate filiation of the child under the Family Code, as the evidence presented, such as hospital bills and photographs, were not signed by Salas; 2) A birth certificate alone is not competent evidence of paternity if the putative father did not sign it; and 3) Baptismal certificates only prove the administration of sacraments, not paternity. The Supreme Court reversed the lower courts and

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    39 views3 pages

    ARTICLE 175 - Narciso Salas Vs Annabelle Matusalem

    Uploaded by

    saminah
    This case involved a petition filed by Narciso Salas challenging a lower court ruling that he was the father of Annabelle Matusalem's child, Christian Paulo Salas, and thus obligated to pay child support. The Supreme Court ruled that: 1) Matusalem did not sufficiently establish the illegitimate filiation of the child under the Family Code, as the evidence presented, such as hospital bills and photographs, were not signed by Salas; 2) A birth certificate alone is not competent evidence of paternity if the putative father did not sign it; and 3) Baptismal certificates only prove the administration of sacraments, not paternity. The Supreme Court reversed the lower courts and

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    of 3

    ARTICLE 175

    G.R. No. 180284


    NARCISO SALAS, Petitioner vs.
    ANNABELE MATUSALEM, Respondent

    FACTS:
    • Annabelle (respondent) filed a complaint for Support/Damages against
    Narciso in the RTC claiming that petitioner is the father of her son Christian
    Paulo Salas. Accordingly, petitioner enticed her as she was then only 24
    years old, making her believe that he is a widower. Petitioner rented an
    apartment where respondent and her child stayed, shouldered all
    expenses in the delivery of their child, including the cost of caesarian
    operation and hospital confinement. When respondent refused the offer of
    petitioner’s family to take the child, petitioner abandoned them.
    • Respondent prayed for support pendente lite and monthly support in the
    amount of 20,000php, as well as actual, moral and exemplary damages,
    and attorney’s fees.
    • Petitioner filed his answer with special and affirmative defenses and
    counterclaims. He denied paternity of the child; and was only motivated
    by genuine altruism.
    • At the trial, respondent and her witness Grace Murillo testified. Petitioner
    was declared to have waived his right to present evidence and the case
    was considered submitted for decision based on respondent’s evidence.
    • The trial court rendered its decision in FAVOR OF RESPONDENT.
    • Petitioner appealed to the CA arguing that: (!) the trial court decided the
    case without affording him the right to introduce evidence on his defense;
    and (2) the trial court erred in finding that petitioner is the putative father of
    Christian Paulo and ordering him to give monthly support. THE CA DISMISSED
    THE APPEAL finding no reason to disturb the trial court’s exercise of discretion
    in denying petitioner’s motion for postponement, scheduled hearing, and
    the motion for reconsideration of the order denying the motion for
    postponement and the submitting the case for decision.
    • On paternity issue, the CA AFFIRMED the trial court’s ruling that respondent
    satisfactorily established the illegitimate filiation of her son Christian Paulo.
    • Petitioner filed a MOTION FOR RECONSIDERATION BUT IT WAS DENIED BY THE
    CA.
    ISSUE:
    Whether or Not the filiation of Christian Paulo as Illegitimate child was duly
    established and therefore entitled to support from petitioner?

    RULING:
    • NO. Under Article 175 of the Family Code of the Philippines, Illegitimate
    filiation may be established in the same way and on the same evidence as
    Legitimate Children.
    Article 172 of the Family Code stated:
    The filiation of legitimate children is established by any of the following:
    (1) The record of birth appearing in the civil registry or a final
    judgment; or
    (2) An admission of legitimate filiation in a public document or a
    private handwritten instrument and signed by the parent
    concerned.
    In the absence of the foregoing evidence, the legitimate filiation shall be
    proved by:
    (1) The open and continuous possession of the status of a legitimate
    child; or
    (2) Any other means allowed by the Rules of Court and Special laws.
    • A certificate of live birth purportedly identifying he putative father is not
    competent evidence of paternity when there is no showing that the
    putative father had a hand in the preparation of the certificate. Thus, is the
    father did not sign in the birth certificate, the placing of his name is
    incompetent evidence of paternity.
    • The court also ruled that while baptismal certificate may be considered as
    public documents, they can only serve as evidence of the administration
    of the sacraments on the dates specified. They are not necessarily
    competent evidence of the veracity of entries therein with respect to child’s
    paternity.
    • The rest of respondent’s documentary evidence consists of handwritten
    notes and letters, hospital bill, and photographs taken of petitioner and
    respondent inside their rented apartment unit are NOT SUFFICIENT TO
    ESTABLISH Christian Paulo’s filiation to petitioner as they were not signed by
    petitioner and contained no statement of admission by petitioner that he is
    the father of said child. Thus, even if those were authentic, they do not
    qualify under Article 172 (2) vis-à-vis Article 175 of the Family Code which
    admits as competent evidence of illegitimate filiation an admission of
    filiation in a private handwritten instrument signed by the parent
    concerned.
    • THE PETITION IS GRANTED. The decision and resolution of the CA are hereby
    REVERSED AND SET ASIDE. Civil case of the RTC is DISMISSED.

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