Republic vs.

Mangotara
[G.R. 170375, July 7, 2010, 624 SCRA,360]
DOCTRINE:
A Baptismal certificate is not totally bereft of probative value. It may be appreciated together with all the
other documentary and testimonial evidence submitted on her filiation like her testimony, birth certificate,
drivers license as well as the death certificate of her grandmother, the family tree and the book showing he
grandmothers descendants
FACTS: The case involved two parcels of land covered by land registration decrees Nos. 10364 and 18969
issued way back in 1914, containing areas of 3,635 square meters and 37.87 hectares respectively and
registered in the name of Delias grandmother, Dona Demetria. After Dona Demetria died in 1974, a certain
Teddy residing in Chicago, USA tried to assert his right to the said lands as son and sole heir by executing an
Affidavit of Adjudication before the Philippine Consulate in Chicago, USA. Since the titles to the land were
not in his possession and could not be located, Teddy executed a Special Power of Attorney in favor of Atty.
Castro, his lawyer in the Philippines, to file a petition before the Regional Trial Court (RTC) for
reconstitution of the original certificates of title (OCT) of said lands. Eventually or in 1997, decrees of
registration bearing Nos. 219464 and 219465 were re-issued. Pursuant to these decrees, OCT No. 0-1200 and
0-1201 covering the two parcels in the name of the late Dona Demetria were reconstituted. Thereafter or on
October 1, 1996 Atty. Castro as the attorney-in-fact of Teddy already sold 27.03 hectares of said land to a
realty company (LTI). Since the OCTs were still in the name of Dona Demetria, Teddy and Atty. Castro also
took steps to register with the Register of Deeds the affidavit of adjudication executed by Teddy. So on
November 18, 1998 upon learning of these moves made by Teddy and his lawyer, Delia filed a Petition for
Quieting of Title before RTC against Teddy, Atty Castro and the Register of Deeds. In the petition Delia
claimed that she and not Teddy was the late Dona Demetrias sole surviving heir. She averred that she is the
daughter of Francisco who was the only child of Demetria with the latters late husband Dionisio.
Delia was joined in her petition by another realty company (AZM) as successor-in-interest over 23 hectare
portion of the subject parcels pursuant to the MOA and Deed of Conditional Conveyance which Delia
executed in its favor. On the other hand, LTI also intervened in the case claiming that it has also acquired 27
hectares of the land from Teddy. During the hearing, Delia and AZM submitted testimonial and
documentary evidence. Delia testified and presented her baptismal certificate, birth certificate, drivers
license, death certificate of her late grandmother Dona Demetria, and the family tree of the showing the
branch of Dona Demetria. In contrast, Teddy, and/or Attorney Castro opted not to adduce any evidence
while LTI failed to present evidence on the scheduled trial date, so it was deemed to have waived its right to
present evidence. Based on the evidence submitted by Delia and AZM, the RTC rendered a decision declaring
Delia as the sole heir of Dona Demetria with the sole hereditary right to the properties, and AZM as her
successor in interest to 23 hectares. It also declared that Teddy is not a son of Dona Demetria while LTI has
no valid right or interest in the property. LTI, Teddy and Atty. Castro questioned this decision before the
Appellate Courts contending that the evidence presented by Delia and AZM was insufficient to prove the fact
of Delias filiation and heir-ship particularly the reliance of the RTC on Delias baptismal certificate, arguing
that it has no probative value and is not a conclusive proof of filiation.
ISSUE: WON evidence presented by Delia and AZM was insufficient to prove the fact of filiation and heirship, particularly the reliance of the RTC on Delias baptismal certificate, arguing that it has no probative
value and is not a conclusive proof of filiation. NO.
HELD: Under Article 172 of the Family Code, the filiation of legitimate children shall be proved by other
means allowed by the Rules of Court and special laws, in the absence of the record of birth or a parents
admission of such legitimate filiation in a public or private document duly signed by the parent. Such other
proof of ones filiation may be a baptismal certificate, a judicial admission, a family Bible in which his name
has been entered, common reputation respecting his pedigree, admission by silence, the testimonies of
witnesses and other kinds of proof under Rule 130 of the Rules of Court.
Thus, Delias baptismal certificate is not totally bereft of probative value. It may be appreciated together with
all the other documentary and testimonial evidence submitted on her filiation like her testimony, birth
certificate, drivers license as well as the death certificate of her grandmother, the family tree and the book
showing her grandmothers descendants.