Pablo Goyma Lim Jr. filed a complaint against the Rodriguez spouses to cancel the certificate of title for two parcels of land, claiming ownership as the acknowledged illegitimate son of Dominga Goyma, the original owner. While Lim provided documents showing he was acknowledged as Dominga's son, the court held that acknowledgment alone is not enough to prove filiation or legal heir status. The Court of Appeals affirmed the lower court's decision in favor of the Rodriguez spouses, finding that Lim's documents were insufficient to prove he was Dominga's legal heir given they did not constitute the formal recognition required by law.
Pablo Goyma Lim Jr. filed a complaint against the Rodriguez spouses to cancel the certificate of title for two parcels of land, claiming ownership as the acknowledged illegitimate son of Dominga Goyma, the original owner. While Lim provided documents showing he was acknowledged as Dominga's son, the court held that acknowledgment alone is not enough to prove filiation or legal heir status. The Court of Appeals affirmed the lower court's decision in favor of the Rodriguez spouses, finding that Lim's documents were insufficient to prove he was Dominga's legal heir given they did not constitute the formal recognition required by law.
Pablo Goyma Lim Jr. filed a complaint against the Rodriguez spouses to cancel the certificate of title for two parcels of land, claiming ownership as the acknowledged illegitimate son of Dominga Goyma, the original owner. While Lim provided documents showing he was acknowledged as Dominga's son, the court held that acknowledgment alone is not enough to prove filiation or legal heir status. The Court of Appeals affirmed the lower court's decision in favor of the Rodriguez spouses, finding that Lim's documents were insufficient to prove he was Dominga's legal heir given they did not constitute the formal recognition required by law.
Pablo Goyma Lim Jr. filed a complaint against the Rodriguez spouses to cancel the certificate of title for two parcels of land, claiming ownership as the acknowledged illegitimate son of Dominga Goyma, the original owner. While Lim provided documents showing he was acknowledged as Dominga's son, the court held that acknowledgment alone is not enough to prove filiation or legal heir status. The Court of Appeals affirmed the lower court's decision in favor of the Rodriguez spouses, finding that Lim's documents were insufficient to prove he was Dominga's legal heir given they did not constitute the formal recognition required by law.
Download as DOCX, PDF, TXT or read online from Scribd
Download as docx, pdf, or txt
You are on page 1of 1
[G.R. No. 135817. November 30, 2006.
] DOCUMENTS PROVING HIS VOLUNTARY
ACKNOWLEDGMENT DO NOT SUFFICE TO PROVE HIS RODRIGUEZ vs. LIM FILIATION TO HIS PARENTS. HELD: The Court has laid down the manner of establishing the filiation of children, whether legitimate or illegitimate, as follows: CALLEJO, SR., J : The filiation of illegitimate children, like legitimate children, is FACTS: Pablo Goyma Lim, Jr. filed with the court a quo a complaint established by (1) the record of birth appearing in the civil register for cancellation of certificate of title and injunction against the or a final judgment; or (2) an admission of legitimate filiation in a spouses Rodriguez. In his complaint, Pablo Goyma Lim, Jr. alleged public document or a private handwritten instrument and signed by that his mother, Dominga Goyma, was the owner of two parcels of the parent concerned. In the absence thereof, filiation shall be land (subject lots). The subject lots were registered in the name of proved by (1) the open and continuous possession of the status of a Dominga Goyma. Dominga Goyma died and was survived by her legitimate child; or (2) any other means allowed by the Rules of only son, Pablo Goyma Lim, Jr., a spurious son acknowledged and Court and special laws. The due recognition of an illegitimate child recognized by her. The complaint also alleged that during her in a record of birth, a will, a statement before a court of record, or lifetime, Dominga Goyma exclusively possessed the subject lots and in, any authentic writing is, in itself, a consummated act of upon her death, Pablo Goyma Lim, Jr. succeeded to all her rights of acknowledgment of the child, and no further action is required. In ownership and possession. However, the spouses Rodriguez, fact, any authentic writing is treated not just a ground for despite their knowledge that Pablo Goyma Lim, Jr., was now the compulsory recognition; it is in itself a voluntary recognition that owner and possessor of the subject lots, allegedly unlawfully and does not require a separate action for judicial approval. fraudulently made it appear that they had purchased the subject Various documentary evidence were proffered by Pablo Goyma Lim, lots from persons who were not the owners thereof. The Jr. to prove that he was the illegitimate and acknowledged son of spouses Rodriguez allegedly tried to enter and occupy the subject Dominga Goyma. lots by force and intimidation. The court rendered judgment in favour of LIM, the Court of Appeals which rendered judgment The Decision of the Court of Appeals is AFFIRMED in toto. affirming in toto the decision of the lower court.
ISSUE: Whether or not RESPONDENTS' PREDECESSOR-IN-
INTEREST, PABLO GO IMA LIM, WAS A CO-OWNER OF THE SUBJECT PROPERTIES AND ENTITLED TO ONE-HALF OF THE SUBJECT PARCELS OF LAND DESPITE THE FACT THAT SAID PABLO GO IMA LIM WAS NOT RECOGNIZED BY HER [SIC] PARENTS AS AN ILLEGITIMATE CHILD AND THE ALLEGED
The Court DISMISSED The Petition. It Sustained The Concurrence of The Philippine Senate of The President's Ratification of The Agreement Establishing The WTO.