- Petitioner
- Yanes
- Respondent
- Republic
- Citation
- G.R. No. 240809
- Court
- Supreme Court
- Decided
- October 1, 2018
Whether petitioner can use the surname 'Yanes' claiming to be the illegitimate child of Luis M. Yanes under Republic Act No. 9255
Summary
Luis Doroteo Yanes petitioned to use the surname 'Yanes,' claiming to be the illegitimate child of Luis M. Yanes under RA 9255. The Supreme Court denied the petition, affirming the Court of Appeals' decision. The Court ruled that despite the birth certificate showing Luis M. Yanes as the father, petitioner is legally presumed to be the legitimate child of his mother's husband, Andres Prado, since he was conceived and born during their marriage. The birth certificate constitutes only prima facie evidence of illegitimacy, which cannot overcome the quasi-conclusive presumption of legitimacy established by Family Code Article 164. This case demonstrates the hierarchy of evidence in establishing paternity and the strong legal presumption favoring legitimacy of children born during marriage.