- Petitioner
- Uyguangco
- Respondent
- Court of Appeals
- Citation
- G.R. No. 76873
- Court
- Supreme Court
- Decided
- October 26, 1989
Whether an alleged illegitimate child can prove filiation to claim inheritance rights in the absence of documentary evidence required by law
Summary
Graciano Bacjao Uyguangco filed a partition suit claiming to be the illegitimate son of deceased Apolinario Uyguangco, seeking share in the estate distributed among legitimate heirs. Despite admitting lack of documentary evidence required under Civil Code Article 278, the trial court allowed him to prove filiation, sustained by the Court of Appeals. However, the Supreme Court applied the newly effective Family Code and dismissed the case. While the Family Code allows proving illegitimate filiation through open and continuous possession of status or other means, such actions must be filed during the alleged parent's lifetime. Since Apolinario died in 1975 and the case was filed after his death, Graciano's claim was time-barred. The Court emphasized that putative parents must have opportunity to affirm or deny alleged filiation, impossible when deceased. The decision demonstrates the transition from Civil Code to Family Code provisions and the strict application of procedural requirements for establishing illegitimate filiation posthumously.