Aguilar v.

Siasat (January 28, 2015)

Facts: Spouses Alfredo and Cadelaria (Aguilar) died without will and leaving two parcels of
land. Rodolfo Aguilar filed a petition for mandatory injunction with damages against Edna
(Siasat) in 1996, alleging that he is the only son of the spouses Alfredo and Candelaria; that when
he searched for the two titles the same cannot be found, and suspected that someone from the
Siasat clan stole it,hence he executed an affidavit of loss, and later filed a petition for issuance of
duplicate owners copy of the titles, which Edna (Siasat) opposed, claiming that the titles were in
her possession, were not stolen, and entrusted to her by her aunt Candelaria, and refused to
surrender the titles.
Rodolfo thus filed the instant case to compel Edna to surrender the titles to him. In her defense,
Edna claimed that Rodolfo is not the son of the spouses Alfredo and Candelaria but a stranger
raised by them merely out of generosity and kind heart. At trial Rodoldo presented documentary
exhibits such as his school records, where Alfredo was indicated as his father; his ITR which
listed Candelaria as her mother, Alfredos SSS E-1 Form which listed Rodolfo as his son; and
other pertinent documents to show his filiation to the spouses. Edna on the other hand presented
the testimonies of Aurea, a sister of Candelaria, who stated that the spouses does not have a son,
though he know of a certain Rodofo with a nickname Mait and that Alfredo had a sister
named Ester. Edna also presented an Affidavit executed by Candelaria announcing that she and
Alfredo had no issue, and she is the sole heir to Alfredos estate.
Issue: W/N the documents presented by Rodolfo by itself did not prove that he is the son of
Alfredo and Candelaria. YES.
Held: The filiation of illegitimate children, like legitimate children, is established by (1) the
record of birth appearing in the civil register or a final judgment; or (2) an admission of
legitimate filiation in a public document or a private handwritten instrument and signed by the
parent concerned. In the absence thereof, filiation shall be proved by (1) the open and continuous
possession of the status of a legitimate child; or (2) any other means allowed by the Rules of
Court and special laws. The due recognition of an illegitimate child in a record of birth, a will, a
statement before a court of record, or in any authentic writing is, in itself, a consummated act of
acknowledgment of the child, and no further court action is required
Thus, applying the foregoing pronouncement to the instant case, it must be concluded that
petitioner who was born on March 5, 1945, or during the marriage of Alfredo Aguilar and
Candelaria Siasat-Aguilar and before their respective deaths has sufficiently proved that he is
the legitimate issue of the Aguilar spouses. As petitioner correctly argues, Alfredo Aguilars
SSS Form E-1 (Exhibit G) satisfies the requirement for proof of filiation and relationship
to the Aguilar spouses under Article 172 of the Family Code; by itself, said document
constitutes an admission of legitimate filiation in a public document or a private
handwritten instrument and signed by the parent concerned. It was erroneous for the CA to
treat said document as mere proof of open and continuous possession of the status of a legitimate
child under the second paragraph of Article 172 of the Family Code; it is evidence of filiation
under the first paragraph thereof, the same being an express recognition in a public instrument.