Rivera v. Heirs of Villanueva
G.R. No. 141501, July 21, 2006
FACTS:
Petitioners are allegedly the half-brothers, the half-sister-in-law, and the children of a half-brother of the deceased Pacita Gonzales. Respondents are heirs of Villanueva and are represented by Melchor. The remaining respondents, Angelina Villanueva and husband Victoriano de Luna, are allegedly the daughter and the son-in-law, respectively, of the late Villanueva. From 1927 until her death in 1980, Gonzales cohabited with Villanueva without the benefit of marriage because the latter was married to one Amanda Musngi who died on April 20, 1963. In the course of their cohabitation, they acquired several properties including the properties contested in this case. Gonzales died on July 3, 1980 without leaving a will. On August 8, 1980, Villanueva and respondent Angelina executed a deed of extrajudicial partition with sale, that is, an extrajudicial settlement of Gonzales’ estate comprising a number of the aforementioned properties. In this document, Villanueva, for the amount of P30,000, conveyed his interests in the estate to Angelina. Petitioners filed a case for partition of Gonzales’ estate and annulment of titles and damages, with the RTC. In dismissing the complaint, the RTC made two findings: (1) Gonzales was never married to Villanueva and (2) respondent Angelina was her illegitimate child by Villanueva and therefore her sole heir, to the exclusion of petitioners. The CA ruled that respondent Angelina was the illegitimate daughter of the decedent, based solely on her birth certificate.
ISSUE:
WON Angelina is an illegitimate child of the deceased Villanueva.
RULING:
No. 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, and even amounts to simulation of the child’s birth or falsification of his or her birth certificate, which is a public document. Furthermore, it is well-settled that a record of birth is merely a prima face evidence of the facts contained therein. It is not conclusive evidence of the truthfulness of the statements made there by the interested parties.Following the logic of Benitez case, respondent Angelina and her co-defendants in SD-857 should have adduced evidence of her adoption, in view of the contents of her birth certificate. The records, however, are bereft of any such evidence. Under the circumstances, the Court ruled that it was not sufficiently established that respondent Angelina was Gonzales’ biological daughter, nor even her adopted daughter. Thus, she cannot inherit from Gonzales. Since she could not have validly participated in Gonzales’ estate, the extrajudicial partition which she executed with Villanueva on August 8, 1980 was invalid.
