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FRANCISCO L. JISON v. CA

FACTS:

This is a petition for review under Rule 45 of the Rules of Court of the 27 April 1995 decision of the Court of Appeals (CA) in CA-G.R. CV No. 32860, which reversed the decision of Branch 24 of the Regional Trial Court (RTC) of Iloilo City in Civil Case No. 16373. The RTC had dismissed the complaint of Monina Jison (hereafter MONINA) for recognition as an illegitimate child of Francisco Jison (hereafter FRANCISCO). MONINA alleged in her complaint filed with the RTC on 13 March 1985, that FRANCISCO impregnated Esperanza F. Amolar, her mother, at the end of 1945 or the start of 1946. MONINA was born on 6 August 1946 in Dingle, Iloilo, and claimed to have been continuously supported by FRANCISCO, including her education leading to her becoming a certified public accountant (CPA) and a Central Bank examiner. In his defense, FRANCISCO denied having sexual relations with Esperanza during the period specified and claimed he ceased to know her whereabouts since 1944. He contended that MONINA's action was barred by estoppel, laches, and/or prescription and sought dismissal of the complaint with an award of damages due to its alleged malicious filing.

At trial, MONINA presented eleven witnesses who testified to her claims, including support provided by FRANCISCO and his implicit recognition of her as his daughter. Witnesses recounted various instances of FRANCISCO's acknowledgment and support, including payment for MONINA's education, visits to his residence, and financial assistance. Many witnesses described FRANCISCO's treatment of MONINA as one of a daughter.

In contrast, FRANCISCO's witnesses included former employees and relatives who generally denied knowledge of MONINA receiving any allowance or other forms of support from FRANCISCO and described MONINA's claims as unfounded. FRANCISCO and his witnesses also emphasized the alleged improbability of MONINA's mother being pregnant by him due to their supposed lack of contact during the relevant period.

The RTC initially ruled in favor of FRANCISCO, finding MONINA's evidence as either hearsay, incredible, or self-serving, and concluded that MONINA's action was barred by estoppel. Upon appeal, the CA found MONINA's evidence preponderant and sufficient to establish her illegitimate filiation to FRANCISCO, hence reversing the RTC's decision and declaring MONINA entitled to the rights of an illegitimate child.

ISSUES:

  1. Whether the Court of Appeals committed reversible error in declaring Monina Jison as the illegitimate daughter of Francisco Jison despite conflicting findings concerning evidence of sexual contact, testimonial credibility, documentary evidence, and the sworn affidavit by Monina.

  2. Whether Monina Jison's action to establish filiation and paternity is barred by laches due to the long and unexplained delay in filing the paternity suit.

RULING:

  1. First Issue

    • The Supreme Court affirmed the decision of the Court of Appeals, ruling that Monina Jison successfully established her filiation as Francisco Jison's illegitimate daughter by "overwhelming evidence," including credible testimonies from multiple witnesses and substantial demonstration of continuous recognition by Francisco Jison and his family. The Court found the testimonial evidence coherent, logical, and exhibiting a pattern of continuous recognition by Francisco of Monina as his daughter.

  2. Second Issue

    • The Supreme Court denied the defense of laches, holding that no element of inequity or injury to Francisco Jison was established. The defense failed to demonstrate that allowing the paternity suit to proceed would be inequitable or unjust, particularly given that filiation-related claims are granted a positive legal timeframe for initiation.

PRINCIPLES:

  1. Family Code of the Philippines Applicability The Family Code applies retroactively if no vested rights are impaired. Evidence to prove illegitimate filiation is governed by Article 175 in relation to Articles 172 and 173 of the Family Code.

  2. Burden of Proof and Preponderance of Evidence In paternity suits, the plaintiff must establish filiation by clear and convincing evidence, and once a prima facie case is made, the burden shifts to the defendant.

  3. Open and Continuous Possession of Status The recognition of an illegitimate child by the putative parent must be continuous and consistent, reflecting a permanent intention to treat the child as one’s own in society and life.

  4. Relevance of Documentary Evidence Birth and baptismal certificates, school records, and letters from relatives, while generally not directly admissible to prove paternity, can be used supplementarily or corroboratively within the witness's testimony.

  5. Laches in Paternity Cases The defense of laches requires showing inequity or prejudice to the defendant resulting from the delay in filing the claim. The doctrine cannot be invoked to defeat justice or perpetuate fraud and injustice.

  6. Notarial Document Contradiction Clear and convincing evidence, stronger than mere preponderance, is necessary to contradict a notarial document.