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    Salas Vs Matusalem

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    Jefferson Mortel
    The Supreme Court of the Philippines ruled that the trial and appellate courts erred in finding that the respondent sufficiently proved the petitioner was the father of her child. The respondent presented a birth certificate listing the petitioner as father but it was not signed by him. Pictures of the mother, child, and alleged father together were also inconclusive. Notes exchanged between the petitioner and respondent expressing affection did not admit paternity. The testimonies regarding circumstances of birth and support were insufficient on their own to establish paternity under Philippine law, which requires a high standard of clear and convincing evidence to prove filiation or paternal obligation.

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    Salas Vs Matusalem

    Uploaded by

    Jefferson Mortel
    1K views2 pages
    The Supreme Court of the Philippines ruled that the trial and appellate courts erred in finding that the respondent sufficiently proved the petitioner was the father of her child. The respondent presented a birth certificate listing the petitioner as father but it was not signed by him. Pictures of the mother, child, and alleged father together were also inconclusive. Notes exchanged between the petitioner and respondent expressing affection did not admit paternity. The testimonies regarding circumstances of birth and support were insufficient on their own to establish paternity under Philippine law, which requires a high standard of clear and convincing evidence to prove filiation or paternal obligation.

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    Salas vs Matusalem

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    The Supreme Court of the Philippines ruled that the trial and appellate courts erred in finding that the respondent sufficiently proved the petitioner was the father of her child. The respondent presented a birth certificate listing the petitioner as father but it was not signed by him. Pictures of the mother, child, and alleged father together were also inconclusive. Notes exchanged between the petitioner and respondent expressing affection did not admit paternity. The testimonies regarding circumstances of birth and support were insufficient on their own to establish paternity under Philippine law, which requires a high standard of clear and convincing evidence to prove filiation or paternal obligation.

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    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as docx, pdf, or txt
    1K views2 pages

    Salas Vs Matusalem

    Uploaded by

    Jefferson Mortel
    The Supreme Court of the Philippines ruled that the trial and appellate courts erred in finding that the respondent sufficiently proved the petitioner was the father of her child. The respondent presented a birth certificate listing the petitioner as father but it was not signed by him. Pictures of the mother, child, and alleged father together were also inconclusive. Notes exchanged between the petitioner and respondent expressing affection did not admit paternity. The testimonies regarding circumstances of birth and support were insufficient on their own to establish paternity under Philippine law, which requires a high standard of clear and convincing evidence to prove filiation or paternal obligation.

    Copyright:

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    of 2

    (Narciso Salas vs.

    Annabelle Matusalem)
    (G.R. No. 180284) | (September 11, 2013) | (Villarama, Jr., J.)

    FACTS: Annabelle Matusalem, filed a complaint for Support/Damages against Narciso


    Salas in the Regional Trial Court (RTC) of Cabanatuan City. Respondent claimed that petitioner
    is the father of her son Christian Paulo Salas. Petitioner, already 56 years old at the time, enticed
    her as she was then only 24 years old, making her believe that he is a widower. Petitioner rented
    an apartment where respondent stayed and shouldered all expenses in the delivery of their child,
    including the cost of caesarian operation and hospital confinement.

    However, when respondent refused the offer of petitioner’s family to take the child from her,
    petitioner abandoned respondent and her child. Respondent further alleged that she attempted
    suicide due to depression but still petitioner refused to support her and their child. Respondent
    thus prayed for support pendente lite and monthly support in the amount of ₱20,000.00.

    On 1999, the trial court rendered its decision in favor of respondent. Petitioner appealed to the
    CA, but the CA affirmed the trial court’s ruling that respondent satisfactorily established the
    illegitimate filiation of her son Christian Paulo, and consequently no error was committed by the
    trial court in granting the respondent’s prayer for support.

    ISSUE: Whether the trial and appellate courts erred in ruling that respondent’s evidence
    sufficiently proved that her son Christian Paulo is the illegitimate child of petitioner

    RULING: Respondent presented the Certificate of Live Birth of Christian Paulo Salas in
    which the name of petitioner appears as his father but which is not signed by him. We have held
    that a certificate of live birth purportedly identifying the putative father is not competent
    evidence of paternity when there is no showing that the putative father had a hand in the
    preparation of the certificate. Thus, if the father did not sign in the birth certificate, the placing of
    his name by the mother, doctor, registrar, or other person is incompetent evidence of paternity.

    Pictures taken of the mother and her child together with the alleged father are inconclusive
    evidence to prove paternity.

    As to the handwritten notes of petitioner and respondent showing their exchange of affectionate
    words and romantic trysts, these, too, are not sufficient to establish Christian Paulo’s filiation to
    petitioner as they were not signed by petitioner and contained no statement of admission by
    petitioner that he is the father of said child.

    Petitioner’s reliance on our ruling in Lim v. Court of Appeals is misplaced. In the said case, the
    handwritten letters of petitioner contained a clear admission that he is the father of private
    respondent’s daughter and were signed by him. The Court therein considered the totality of
    evidence which established beyond reasonable doubt that petitioner was indeed the father of
    private respondent’s daughter.
    Here, while the CA held that Christian Paulo Salas could not claim open and continuous
    possession of status of an illegitimate child, it nevertheless considered the testimonial evidence
    sufficient proof to establish his filiation to petitioner.

    An illegitimate child is now also allowed to establish his claimed filiation by "any other means
    allowed by the Rules of Court and special laws. Reviewing the records, we find the totality of
    respondent’s evidence insufficient to establish that petitioner is the father of Christian Paulo. The
    testimonies of respondent and Murillo as to the circumstances of the birth of Christian Paulo,
    petitioner’s financial support while respondent lived in Murillo’s apartment and his regular visits
    to her at the said apartment, though replete with details, do not approximate the "overwhelming
    evidence, documentary and testimonial" presented in Ilano. 

    In sum, we hold that the testimonies of respondent and Murillo, by themselves are not competent
    proof of paternity and the totality of respondent’s evidence failed to establish Christian Paulo’s
    filiation to petitioner.

    Time and again, this Court has ruled that a high standard of proof is required to establish
    paternity and filiation. An order for recognition and support may create an unwholesome
    situation or may be an irritant to the family or the lives of the parties so that it must be issued
    only if paternity or filiation is established by clear and convincing evidence.

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