Mangulabnan v. Acero

Summary

This case involves an illegitimate child's right to support pendente lite from the alleged father. Edna Padilla Mangulabnan, as guardian for minor Alfie Angelo, sued Ambrocio Tan Chew Acero for support. The Regional Trial Court granted P1,500 monthly support, but the Court of Appeals reversed, holding that illegitimate children must be recognized before claiming support. The Supreme Court reversed the appellate court, clarifying that while natural children require recognition under Article 276 of the Civil Code, illegitimate children who are not natural children (spurious children) need only prove filiation, not recognition, to claim support. The Court distinguished that since the father was married and lacked legal capacity to marry at conception, the child was spurious, not natural. The case established that filiation can be provisionally proven through affidavits and birth certificates for support pendente lite purposes. The decision reinforced the rights of illegitimate children to support from their parents without the additional burden of formal recognition required for natural children.