- Petitioner
- Cabatania
- Respondent
- Court of Appeals
- Citation
- G.R. No. 124814
- Court
- Supreme Court
- Decided
- October 21, 2004
Recognition of illegitimate filiation and support obligation
Summary
This case involves a petition for recognition of illegitimate filiation and support filed by Florencia Regodos for her minor son Camelo Regodos against alleged father Camelo Cabatania. Florencia claimed sexual intercourse with Cabatania in January and March 1982, resulting in the child's birth in September 1982. Both lower courts granted recognition and support based on the mother's testimony and the child's physical resemblance to petitioner. The Supreme Court reversed, establishing that high standards of proof are required for paternity cases. The Court held that birth and baptismal certificates are inadmissible as proof of filiation without the putative father's participation, and physical resemblance is insufficient evidence in the modern age of genetic testing. The mother's misrepresentation about being a widow when her husband was alive created a presumption of legitimacy for the child born during the valid marriage, defeating the illegitimate filiation claim.