Tayag v. Court of Appeals

Summary

This case involves an illegitimate minor child's claim for inheritance from his deceased putative father's estate. Emilie Dayrit Cuyugan, as guardian of minor Chad D. Cuyugan, sued Corito Ocampo Tayag, administratrix of Atty. Ricardo Ocampo's estate, claiming Chad's inheritance rights. The Supreme Court affirmed that an illegitimate child may join causes of action to compel recognition and claim inheritance in one complaint, citing Briz vs. Briz. The Court applied Article 285 of the Civil Code rather than the Family Code's Article 175, holding that the right was vested when the complaint was filed under the Civil Code regime. The Court ruled the action had not prescribed since it was filed during the child's minority and the putative father died during the child's minority, allowing four years from attainment of majority. The decision establishes important precedent on joinder of causes of action in filiation and inheritance cases and the application of transitional provisions between the Civil Code and Family Code.