Petitioner
De Jesus
Respondent
Estate of Dizon
Citation
G.R. No. 142877
Court
Supreme Court
Decided
October 2, 2001

Whether children born in lawful wedlock can claim to be illegitimate children of another person to assert inheritance rights in a partition action

Summary

Two children born during their parents' marriage sought to claim inheritance from Juan G. Dizon's estate based on his notarized acknowledgment of them as his illegitimate children. The Supreme Court denied their petition, ruling that children born in wedlock are presumptively legitimate under the Family Code, and this presumption becomes conclusive absent proof of physical impossibility of spousal access. The Court held that petitioners cannot impugn their own legitimate status to claim illegitimate filiation to another person for inheritance purposes. Only the husband or his heirs can contest a child's legitimacy in a direct action specifically brought for that purpose. The case establishes that legitimacy cannot be attacked collaterally through partition proceedings, and that written acknowledgment by an alleged father cannot override the legal presumption of legitimacy for children born in wedlock. This decision reinforces the Family Code's strong protection of legitimate filiation and the procedural requirements for challenging such status.

Statutes applied

Related cases

Other Philippine cases on the same provisions and issues.

Featured in research

In-depth Intellegal research that discusses this case.

By the Intellegal Editorial Board · October 2, 2001

Search Philippine case law on Intellegal →
AI-assisted case analysis — for research only. Verify against the official decision. A research aid, not legal advice; using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer. Verify every holding and citation against the official decision (Supreme Court E-Library / Official Gazette) before relying on it.