Geronimo vs.

Santos ( Filiation NOT Established)

Facts:
1) Plaintiff Santos claimed to be the only child of the deceased
spouses Rufino and Caridad Geronimo. She filed a complaint for
annulment of document ( Pagmamana sa Labas ng Hukuman) and
recovery of a parcel of land against the defendants who were the
brothers of Rufino.
2) She alleged that the said document declared the defendants as the
sole heirs of spouses. Also, upon the death of her parents, all their
propertied should be passed down to her and not to the defendants.
3) The defendants denied the allegations and said that Santos was an
adopted child of the spouses and was a daughter of caridads sister.
They also presented the birth certificate of the plaintiff and
contended the irregularity of the document due to tampered
markings.
RTC: Ruled in favor of the plaintiff. The court declared the document null and
void and ordered the return of the land to Santos, who was declared as
legitimate child of the spouses based on the birth certificate presented and
the open and continuous possession of the status as legitimate child which
established her filiation.
CA: AFFIRMED RTCs Decision
ISSUE: WON the filiation of the plaintiff was duly established based on the
grounds provided by law.
HELD:NO. The SC disagrees with both courts and rule that the confluence
of the circumstances and proofs presented in this case do not lead to the
conclusion that the respondent is a child of the deceased.
Both courts misapprehended the facts: The RTC relying on the
questionable BC and the appellate court affirming the trial courts decision
based on the continuous possession of status by Santos did not adequately
established the filiation of plaintiff.
It was evident that the BC was tampered with questionable markings. A
representative from NSO confirmed this and the fact that Karen did not even
offer evidence to explain such irregularity are sufficient to overthrow the
presumption of legitimacy.
The secondary evidence did not sufficiently established that the plaintiff was
indeed the child of the spouse. In a similar jurisprudence, the court ruled that
the presence of a similar set of circumstances which were relied upon as
secondary proof by both courts a quo in the case at bar does not establish
that one is a child of the putative parents. The the mere registration of a
child in his or her birth certificate as the child of the supposed parents
is not a valid adoption, does not confer upon the child the status of an
adopted child and the legal rights of such child
Petition GRANTED.