Professional Documents
Culture Documents
Facts:
Spouses Alfredo and Cadelaria (Aguilar) died without will and without debts in 1983 and
1994, respectively, leaving two parcels of land. Rodolfo filed a petition alleging that he is the
only son of the spouses Alfredo and Candelaria; that he suspected the two titles of the land
was stolen by someone from the Siasat clan, which Edna opposed, claiming that the titles
were in her possession, were not stolen, and entrusted to her by her aunt Candelaria.
In her defense, Edna claimed that Rodolfo is not the son of the deceased spouses but a
stranger raised by them merely out of generosity and kind heart; that Alfredo predeceased
Candelaria, thus the latter inherited his conjugal share; upon her death, her brothers and
sisters inherited the estate of Candelaria, and the titles were entrusted to her by Candelaria,
her aunt.
At trial Rodolfo presented documentary exhibits such as his school records, where Alfredo
was indicated as his father; his ITR which listed Candelaria as her mother; deceased
Alfredos Social Security System (SSS) Form E-1, a public instrument subscribed and made
under oath by him during his employment, which bears his signature and thumb marks and
indicates that petitioner, who was his son and dependent; and other pertinent documents to
show his filiation to the spouses.
Edna also presented an Affidavit executed by Candelaria announcing that she and Alfredo
had no issue, and she is the sole heir to Alfredos estate.
The RTC rendered judgment in favor of Edna since Rodolfo failed to present any evidence
that he is the biological son of Alfredo and Edna, further complicated by the lack of a
certificate of live birth and the affidavit of Candelaria that she had no issue.
In his appeal to the CA, Rodolfo argued that his failure to present a Certificate of Live Birth
was by reason of the destruction of all records at the Local Civil Registry; that under Article
172 of the Family Code, an admission of filiation in a public document or a private
handwritten document signed by the parent constitute proof of filiation, which he sufficiently
proved by his documentary exhibits.
The CA ruled otherwise, averring that the documents presented by Rodolfo do not establish
pedigree.
ISSUE: