Jose Rivero v. Court of Appeals

Summary

This case involves a disputed compromise agreement where Mary Jane Dy Chiao-De Guzman recognized Benedick Arevalo as her deceased father's illegitimate son in exchange for P6 million from the estate, leading to property auctions worth P20 million. The Supreme Court upheld the Court of Appeals' nullification of the RTC decision, establishing crucial precedents that filiation cannot be compromised under Article 2035 of the Civil Code, and that recognition of illegitimate children must be made personally by the putative parent. The Court found extrinsic fraud in the compromise's execution, noting that Mary Jane lacked proper authority to bind her mentally incompetent brothers who were hospital patients. The decision declared the entire chain of transactions - compromise agreement, court judgment, execution, and property sales - null and void, emphasizing the non-compromisable nature of civil status and the strict requirements for valid representation of incompetent parties in legal proceedings.