Rodriguez v. Court of Appeals

Summary

This case resolved whether a mother can testify to identify the putative father in a compulsory recognition action. The Supreme Court distinguished between voluntary and compulsory recognition, ruling that Article 280's prohibition on revealing the father's identity applies only to voluntary acknowledgment, not court-ordered recognition proceedings. The Court traced the historical development from Spanish Civil Code provisions and noted that the Family Code liberalized paternity investigation rules. The decision affirmed the Court of Appeals' ruling allowing the mother's testimony, establishing important precedent for evidence in paternity cases. This case significantly clarified the scope of Article 280 and strengthened children's rights to establish filiation through available evidence in compulsory recognition actions.