Petitioner
Micaela Borres
Respondent
The Municipality of Panay
Citation
G.R. No. 15851
Court
Supreme Court
Division
First Division
Ponente
Villamor, J.
Decided
January 11, 1922

Summary

The Municipality of Panay challenged Micaela Borres' right to inherit from her deceased acknowledged natural child Pio Nono Bidiones, claiming the estate should escheat to the government because the child was allegedly adulterous and improperly acknowledged. The Supreme Court affirmed the lower court's ruling in favor of the natural mother, establishing important precedent on inheritance rights of natural parents. The Court held that the Civil Code grants reciprocal inheritance rights between natural parents and their acknowledged natural children, and that acknowledgment by one parent cannot be contested by investigating the identity or marital status of the non-acknowledging parent, as this would violate the Code's prohibition against paternity investigations. The decision reinforced that adopted children retain inheritance relationships with their natural parents under the Code of Civil Procedure, and that the presumption of natural filiation under Article 130 cannot be overcome through prohibited paternity investigations.

Statutes applied

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By the Intellegal Editorial Board · January 11, 1922

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