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HEIRS OF PAULA C. FABILLAR v. MIGUEL M. PALLER

FACTS:

The case involves a dispute over the ownership and possession of a 3.1003-hectare parcel of agricultural coconut land in Giporlos, Eastern Samar. The respondents claim that the land was originally owned by their grandfather, Marcelino Paller, and was orally partitioned among his children, including their father, Ambrosio Paller. They argue that through succession, they are the rightful owners of the subject land. On the other hand, the petitioners claim to be legitimate and compulsory heirs of Marcelino, and that the land has not been partitioned and is commonly owned by Marcelino's heirs. They dispute Ambrosio's filiation to Marcelino and his right to claim the land.

The Municipal Circuit Trial Court (MCTC) ruled in favor of the respondents, declaring them as the lawful owners of the land. The Regional Trial Court (RTC) affirmed the MCTC's ruling. On appeal to the Court of Appeals (CA), the CA upheld the RTC's ruling, finding that Ambrosio is a child of Marcelino and that the respondents have a right over the land.

The petitioners, heirs of Paula, filed a petition for review on certiorari questioning the CA's decision.

ISSUES:

  1. Whether or not a special proceeding for declaration of heirship is necessary to establish the filiation of Ambrosio to Marcelino.

  2. Whether or not Ambrosio's baptismal certificate is competent proof of his filiation.

  3. Whether the evidence presented by the respondents is sufficient to establish that the two-hectare parcel of land subject of the unnotarized deed of sale is a portion of the subject land.

  4. Whether the boundaries stated in the unnotarized deed of sale coincide with the boundaries stated in the tax declaration.

  5. Whether the tax receipts submitted by the respondents correspond to the subject land.

RULING:

  1. A special proceeding for declaration of heirship is not necessary in this case. Both parties voluntarily submitted the issue of heirship to the trial court, and the trial court is empowered to make a declaration of heirship for the purpose of resolving the issue of ownership. Recourse to administration proceedings to determine the heirs is only necessary if there are good and compelling reasons for it, which are absent in this case.

  2. Ambrosio's baptismal certificate is not considered competent proof of his filiation. While a baptismal certificate may be considered as evidence of the administration of the sacrament on the specified date, it has scant evidentiary value in establishing filiation or parentage. Other pieces of evidence must be perused to resolve disputed filiation, and the burden of proof is on the party claiming filiation to establish it. In this case, the courts did not find any other material proof related to the baptismal certificate that would establish Ambrosio's filiation with Marcelino.

  3. The Court found that the evidence presented by the respondents is insufficient to establish that the two-hectare parcel of land subject of the unnotarized deed of sale is a portion of the subject land. The boundaries stated in the unnotarized deed of sale do not coincide with the boundaries stated in the tax declaration. Furthermore, the tax receipts submitted by the respondents do not correspond to the subject land. Therefore, the Court reversed the decision of the Court of Appeals and dismissed the amended complaint filed by the respondents.

PRINCIPLES:

  • A special proceeding for declaration of heirship may be dispensed with if the parties voluntarily submit the issue of heirship to the trial court and present their evidence.

  • A baptismal certificate alone is not sufficient to establish filiation and must be considered alongside other evidence of filiation.

  • The burden of proof is on the party claiming filiation to establish it, and a baptismal certificate is not conclusive proof of filiation.

  • The burden of proof rests upon the party who asserts the affirmative of an issue. In this case, the burden of proof rests upon the respondents to establish that the two-hectare parcel of land is a portion of the subject land.

  • Tax declarations are competent evidence of ownership and possession of the land to which they refer. In this case, the tax declaration with the correct boundaries is TD No. 6618, and the tax receipts submitted by the respondents do not correspond to this tax declaration.

  • In order for a pseudonym to be considered valid and legally recognized, it must either be assumed for literary purposes or authorized by a competent court. In this case, there is no evidence to establish that "Marcos" was assumed as a pseudonym for literary purposes or authorized by a competent court.