Barles v. Enrile
REITERATIONFacts
The Antecedents: Plaintiffs, Lilia Juana Barles, Maria Estrella Barles, and Remedios Barles, filed a "peticion para el reconocimiento de filiacion paternal con dano moral" against Alfonso Ponce Enrile, alleging they are his illegitimate issue with Genoveva Barles. Procedural History: The defendant filed a motion to dismiss, which was deferred. The case was transferred to the Juvenile and Domestic Relations Court upon its organization. The Juvenile and Domestic Relations Court dismissed the complaint without going into the merits, holding that the action had prescribed. Plaintiffs appealed. The Petition: Plaintiffs appealed the dismissal, arguing that the lower court misapplied the law on prescription regarding their action to establish paternity.
Issue(s)
Whether the plaintiffs' action to establish paternity of illegitimate children had prescribed. Whether Article 285 of the new Civil Code, concerning the time limitation for actions for recognition of natural children, applies to actions for investigation of paternity of spurious children.
Ruling
The appealed decision is reversed, and the case is remanded to the lower court for further proceedings. The motion for reconsideration is denied.
Ratio Decidendi
On Whether the plaintiffs' action to establish paternity of illegitimate children had prescribed: The lower court erred in holding that the plaintiffs' action accrued from birth and was barred by prescription under the old Code of Civil Procedure. The action is authorized under Article 289 of the new Civil Code, which permits the investigation of paternity of illegitimate (spurious) children under circumstances specified in Articles 283 and 284. The new Civil Code does not specify a period for this action. However, it is similar to the action for compulsory recognition of natural children under Article 285, which must be brought during the lifetime of the presumed parents, with certain exceptions. Since the action was filed during the lifetime of the presumed parent, it was not barred by prescription. The time for prescription is counted from the day the action may be brought, not from birth. Furthermore, Articles 283, 284, and 289 of the new Civil Code, concerning proof of illegitimate filiation, are expressly given retroactive effect under Article 2263. On Whether Article 285 of the new Civil Code applies to actions for investigation of paternity of spurious children: The contention that Article 285, which limits the action for recognition of natural children to the lifetime of the presumed parents (with exceptions), does not apply to spurious children is untenable. This Court has consistently ruled that such actions are similar and should have the same time limitation in the absence of an express legal provision to the contrary. Public policy is involved in actions for acknowledgment of natural children, which explains the special period of prescription. Article 1148 of the new Civil Code clarifies that limitations of action in a specific title are without prejudice to those specified elsewhere. The opinion of Mr. Justice J.B.L. Reyes in Zuzuarregui vs. Zuzuarregui supports the view that Article 285 applies not only to natural children but also to actions for investigation of paternity by illegitimate children.
Main Doctrine
The action to investigate the paternity of illegitimate (spurious) children, as authorized under Article 289 of the new Civil Code, is similar to the action for compulsory recognition of natural children under Article 285 of the same Code, and thus may be brought during the lifetime of the presumed parent, unless specific exceptions apply. The time limitation for such actions should be the same in the absence of an express legal provision to the contrary.