FACTS:

The late Spouses Dr. Jose K. Fernandez and Generosa A. de Venecia owned a parcel of land and a two-storey building in Dagupan City. They purchased a baby boy named Rodolfo Fernandez from a certain Miliang for P20.00. Rodolfo lived with the couple until they became old and disabled. Jose K. Fernandez died, leaving his wife Generosa de Venecia and Rodolfo Fernandez as the surviving heirs. They executed a Deed of Extra-judicial Partition dividing the property between them. Generosa also executed a Deed of Absolute Sale in favor of Eddie Fernandez, Rodolfo's son, over a portion of the land. Upon learning of the transaction, the nephews and nieces of Jose K. Fernandez filed an action to declare the Extra-Judicial Partition and Deed of Sale void ab initio. They alleged that the defendants, motivated by greed, deprived them of their rightful inheritance through fraudulent and fabricated contracts. They sought the nullification of the said contracts. In their answer, the defendants claimed that the deceased spouses acknowledged Rodolfo as their child and that the contracts were executed with full knowledge and consent of the parties. The Regional Trial Court rendered a decision in favor of the plaintiffs, declaring the Deed of Extra-Judicial Partition and Deed of Absolute Sale void.

The plaintiffs filed a complaint for declaration of nullity of documents, partition, recovery of possession, and damages against the defendants. The trial court ruled in favor of the plaintiffs, declaring the extrajudicial partition, deed of absolute sale, and corresponding titles null and void. The court also ordered the defendants to reconvey the property and to pay compensatory damages, moral damages, attorney's fees, and litigation costs. The trial court found that the defendant, Rodolfo Fernandez, was not a legitimate or legally adopted child of the spouses Dr. Jose Fernandez and Generosa de Venecia Fernandez. The court cited various evidence including the absence of a birth certificate, inconsistencies in the records, and a questionable baptismal certificate. The defendants appealed to the Court of Appeals, but their appeal was denied. They then filed a petition for review with the Supreme Court, raising several issues including the ownership of the property and the legitimacy of Rodolfo Fernandez.

The case involves the rights to the conjugal property of the deceased spouses Fernandez. The respondent court declared the extra-judicial partition executed by petitioner Rodolfo Fernandez and Generosa Fernandez, widow of Dr. Jose Fernandez, null and void. This was based on the alleged failure of Rodolfo Fernandez to prove his legitimate filiation to his putative father, the late Dr. Jose Fernandez. The petitioners argue that the burden of proof lies with the respondents, who contested Rodolfo's filiation, and that the lower courts had no power to decide on the matter of filiation. The respondents' main action was for the nullity of the extrajudicial partition and absolute sale, and not to impugn Rodolfo's legitimacy. However, the court ruled on Rodolfo's filiation to determine his right to the extra-judicial partition as the alleged legitimate heir of the Fernandez spouses. The case of Benitez-Badua vs. Court of Appeals, which had a similar factual backdrop, was cited.

ISSUES:

1. Filiation and Heirship

   • Whether Rodolfo Fernandez was a legitimate child of the deceased spouses Dr. Jose K. Fernandez and Generosa A. de Venecia, and thereby an heir to their estates.

2. Validity of Contracts

   • Whether the Deed of Extra-Judicial Partition and the Deed of Absolute Sale were valid and enforceable.

3. Third-Party Right to Challenge Contracts

   • Whether the respondents, being third parties, had the right to question the validity of the contracts, particularly the Deed of Sale.

4. Damages and Attorney's Fees

   • Whether the award of actual and moral damages and attorney's fees to the respondents by the lower courts was justified.

RULING:

1. Filiation and Heirship

   • The Supreme Court agreed with the lower courts that Rodolfo Fernandez failed to prove his filiation with the deceased spouses. Consequently, Rodolfo was not considered a legitimate child or legal heir.

2. Validity of Contracts

   • The Deed of Extra-Judicial Partition executed by Rodolfo Fernandez and Generosa A. de Venecia was declared null and void insofar as Rodolfo's share was concerned. The Deed of Sale was upheld as valid for the portion legitimately belonging to Generosa A. de Venecia.

3. Third-Party Right to Challenge Contracts

   • The respondents, as legal heirs to Dr. Jose K. Fernandez, had the right to challenge the Deed of Sale executed by Generosa to protect their share of the inheritance. As a result, the sale was valid only to the extent of Generosa’s ¾ share in the property. Respondents maintained their ¼ share.

4. Damages and Attorney's Fees

   • The Court found no factual and legal basis for awarding actual and moral damages and attorney's fees, and thus, these awards were deleted.

PRINCIPLES:

1. Burden of Proof in Filiation Claims

   • The burden of proof in establishing filiation lies with the claimant. Filiation must be proven with proper and admissible evidence.

2. Action to Impugn Legitimacy

   • An action to impugn the legitimacy of a child can generally be brought only in a direct action by the proper parties and not collaterally. However, if the claim pertains to whether an individual was ever born to a particular couple, this specific issue can be addressed in actions involving property or succession.

3. Public Documents as Evidence

   • Entries in public records are considered prima facie evidence of the facts they assert. However, their validity and the truthfulness of such assertions are not absolute and can be challenged.

4. Invoicing Rights

   • Contracts, including deeds of sale, executed under legal formalities and with proper consideration, are valid. Third parties affected by such contracts have the legal standing to question their validity if they can demonstrate direct detriment to their own rights and interests.

5. Damages and Attorney’s Fees

   • To award actual, moral, or other forms of damages, a factual basis must be clearly established and proven in court. Similarly, attorney’s fees require specific legal justification.