FACTS:

The case involves a dispute over the partition of properties of the late Josefa Ara. Romeo F. Ara and William A. Garcia, together with Dra. Fely S. Pizarro and Henry A. Rossi, claimed to be children of Josefa Ara. However, respondent Pizarro disputed their claims. The trial court initially declared that all plaintiffs and defendant are co-owners of the properties in equal shares. Respondent Pizarro appealed the decision, claiming that petitioners Ara and Garcia should not be included in the partition. Petitioners Ara and Garcia, as well as respondent Rossi, also filed their respective appeals challenging different aspects of the Trial Court's decision. The Court of Appeals partially granted the appeals, affirming the Trial Court's decision with modifications. The Court of Appeals excluded petitioners Ara and Garcia from the enumeration of Josefa's descendants, reversing the finding of the Trial Court. The Court of Appeals found that the Trial Court erred in allowing petitioners to prove their status as illegitimate children of Josefa after her death. Petitioners, together with respondent Rossi, filed motions for reconsideration, which were denied by the Court of Appeals. Petitioners now bring a Petition for Review on Certiorari before the Supreme Court to challenge the Court of Appeals' application of the law on establishing filiation.

The petitioners sought to establish their filiation through various documents, such as baptismal certificates, marriage certificates, and photographs. However, these documents do not fall under the first paragraph of Article 172 of the Family Code, which enumerates the evidence for establishing filiation. The petitioners also presented additional evidence, such as a statement from a family member and the testimony of a witness, to support their claim. These evidence, however, were not considered as sufficient proof of filiation under the law. Furthermore, the petitioners failed to present evidence that would prove their illegitimate filiation to their putative parent after her death, as required by Articles 172 and 175 of the Family Code.

The court recognizes that birth certificates typically offer prima facie evidence of filiation and require a high degree of proof to overthrow the presumption of truth. However, in this case, the delayed registration raises doubts about its accuracy and reliability. The court cites Act No. 3753, which provides that the declaration of the physician or midwife in attendance at the birth, or in default thereof, the declaration of either parent of the newborn child, is sufficient for the registration of a birth in the civil register. The declaration should be sent to the local civil registrar within thirty days after the birth and include information such as the date and hour of birth, sex and nationality of the infant, names, citizenship, and religion of the parents, civil status of parents, place of birth, and other required data.

ISSUES:

1. Whether the petitioner's Certificate of Live Birth obtained through late registration is a record of birth appearing in the civil register under Article 172 of the Family Code.

2. Whether the Certificate of Live Birth obtained through late registration should be accorded the same weight as any other birth certificate.

3. Whether or not the delayed registration of birth of Garcia is valid.

4. Whether or not the birth certificates naming the putative father as the father of illegitimate children are competent evidence of paternity.

5. Whether the delayed registration of birth can be considered conclusive evidence of filiation.

6. Whether the open and continuous possession of the status of filiation can be used to prove illegitimate filiation after the death of the putative parent.

7. Whether the action for recognition of natural children can still be filed after the death of the alleged parent.

8. Whether the birth certificates submitted by respondent Pizarro are credible evidence of petitioners' filiation.

9. Whether the delayed registration of William Garcia's birth should be disregarded.

10. Whether the Court of Appeals erred in finding that respondents are the children of Josefa.

RULING:

1. The petitioner's Certificate of Live Birth obtained through late registration is not considered a record of birth appearing in the civil register under Article 172 of the Family Code.

2. The circumstances surrounding the delayed registration prevent according the Certificate of Live Birth obtained through late registration the same weight as any other birth certificate.

3. The delayed registration of birth of Garcia is valid. The requirements for delayed registration of birth have been complied with, including the submission of a delayed registration of birth, holding a hearing for the delayed registration, and the absence of opposition to the registration.

4. The birth certificates naming the putative father as the father of illegitimate children are not competent evidence of paternity. The certificates must be signed by the putative father or show his participation in preparing the certificates. Without his participation, the certificates are not proof of voluntary acknowledgment of paternity.

5. The delayed registration of birth is not conclusive evidence of filiation. It merely has prima facie evidentiary value and can be rejected if there are circumstances that cast doubt on its veracity.

6. The open and continuous possession of the status of filiation can only be used to prove illegitimate filiation if it is proven during the lifetime of the putative parent. It cannot be used as evidence after the death of the parent.

7. The Court ruled that the action for recognition of natural children must be brought during the lifetime of the alleged parent. Since the alleged parent, Josefa Ara, has already passed away, the petitioners can no longer introduce evidence of their open and continuous illegitimate filiation to Josefa.

8. The Court upheld the birth certificates submitted by respondent Pizarro as credible evidence, as issued by the Civil Registry. Therefore, it was determined that the birth certificates did not name Josefa as the parent of the petitioners, thereby establishing that petitioners are not the children of Josefa Ara.

9. The Court of Appeals did not err in disregarding the delayed registration of William Garcia's birth, considering that there were two reports of birth for him and one was made only after initiating a case which would directly use said report. The appreciation of evidence is not subject to inquiry in a petition for review under Rule 45.

10. The Court of Appeals did not err in sustaining the Trial Court's determination that respondents Pizarro and Rossi were the children of Josefa, as respondents' filiation with Josefa was not put in question before the Trial Court and even petitioners admitted in their Complaint that respondents were Josefa's children.

PRINCIPLES:

• Birth certificates offer prima facie evidence of filiation and enjoy a high degree of evidentiary value.

• To overthrow the presumption of truth contained in a birth certificate, a high degree of proof is required.

• Birth certificates must be registered within 30 days from the time of birth and must be certified by the attendant at birth or the parents.

• Delayed registration of birth is allowed under certain conditions, as provided by law and regulations.

• The requirements for delayed registration of birth must be complied with to make the registration valid.

• Birth certificates naming the putative father as the father of illegitimate children must be signed by the father or show his participation in preparing the certificates to be competent evidence of paternity.

• A delayed registration of birth is tenuous proof of filiation and does not have the same evidentiary weight as regular birth certificates.

• Even without a record of birth or a final judgment, filiation can still be established through an admission of filiation in a public document or a private handwritten instrument, signed by the parent concerned.

• An admission is an act, declaration, or omission of a party on a relevant fact, which may be used in evidence against him.

• The open and continuous possession of the status of filiation can only be used as evidence if it is proven during the lifetime of the putative parent. It cannot be used after the death of the parent.

• An action for recognition of natural children must be brought during the lifetime of the alleged parent.

• In the absence of a record of birth appearing in the civil register or a final judgment, an express admission of filiation in a public document, or a handwritten instrument signed by the parent concerned, a deceased person has no opportunity to contest a claim of filiation.

• Public documents, such as birth certificates, are considered trustworthy and their entries are given value, unless there is strong, complete, and conclusive proof of their falsity or nullity.

• Delayed registration of birth may be disregarded if there are inconsistencies or questionable circumstances surrounding the registration process.

• The determination of filiation is a matter of evidence and may be upheld if not put into question during the trial.