Manuel de Asis v. Court of Appeals

Summary

This Supreme Court case involved a petition for certiorari challenging the denial of a motion to dismiss a support case on grounds of res judicata. Manuel de Asis argued that a previous support case filed by the same minor (through her mother) was dismissed with prejudice in 1989 after the mother manifested it was futile to claim support since he denied paternity. When a new support case was filed in 1995, de Asis moved to dismiss claiming res judicata. The Supreme Court dismissed the petition, holding that the right to receive support cannot be renounced or compromised under Articles 301 and 2035 of the Civil Code. The Court ruled that the previous manifestation amounted to prohibited renunciation of support rights, and that paternity issues must be judicially determined, not left to parties' agreements. Even dismissals with prejudice cannot bar subsequent support actions as the right to support is founded on public policy protecting the recipient's existence and cannot be waived.