Case Digest: JOAQUIN v. REYES

Joaquin v. Reyes
G.R. No. 154645, July 13, 2004

FACTS:

Respondents filed a Complaint for reconveyance and damages, dated January 23, 1982, before the Court of First Instance of Rizal, containing the following allegations:

1. Lourdes P. Reyes was the widow of Rodolfo A. Reyes who died on September 12, 1981.
2. Respondents Mercedes, Manuel, Miriam and Rodolfo, Jr. were the legitimate children of respondent Lourdes P. Reyes and the deceased Rodolfo A. Reyes;
3. That 4 years before his death, Rodolfo A. Reyes had illicit relations with petitioner Milagros B. Joaquino and such relationship bore children
4. Before his death, Rodolfo A. Reyes was Vice President and Comptroller of Warner Barnes and Company with an income of P15,000.00 a month and, after retirement on September 30, 1980, received from said company benefits and emoluments in the amount of P315,011.79; that respondent wife was not the recipient of any portion of the said amount.
5. On July 12, 1979, a Deed of Sale of a property consisting of a house and lot at BF Homes, Parañaque, Metro Manila was executed by the spouses Ramiro Golez and Corazon Golez in favor of petitioner Milagros B. Joaquino
6. The funds used to purchase this property were conjugal funds and earnings of the deceased Rodolfo A. Reyes as executive of Warner Barnes and Company as petitioner Joaquin was without the means to pay for the same;
7. Petitioner executed a Special Power of Attorney in favor of Rodolfo A. Reyes to mortgage the property in order to pay the balance of the purchase price;

It was petitioner’s submission that her children are entitled to a share in the disputed property, because they were voluntarily acknowledged by Rodolfo as his children.

ISSUE:

Whether or not the ruling on the filiation and the successional rights of petitioner’s children was correct.

RULING:

No. The Court held that the status of an illegitimate child who claimed to be an heir to a decedent’s estate could not be adjudicated in an ordinary civil action which, as in this case, was for the recovery of property.

Matters relating to the rights of filiation and heirship must be ventilated in the proper probate court in a special proceeding instituted precisely for the purpose of determining such rights. In Agapay v. Palang, the Court held that the status of an illegitimate child who claimed to be an heir to a decedent’s estate could not be adjudicated in an ordinary civil action which, as in this case, was for the recovery of property.