Mejia v. Mejia
REITERATIONFacts
The Antecedents: Plaintiffs alleged they were voluntarily recognized illegitimate children of the deceased Teofilo Mejia, who died in 1942. They instituted a case against the widow, Casilda M. de Mejia, for the partition of eight parcels of land claimed to be part of the conjugal partnership and for damages due to the refusal to recognize their claim and share in the products. Procedural History: The defendant filed an answer denying the allegations and asserting special defenses, including the statute of limitations and that the lands belonged to Hacienda Casilda, Inc. The lower court, after requiring memoranda, dismissed the complaint, holding that under the Spanish Civil Code, adulterous children were only entitled to support, and the new Civil Code of the Philippines, granting successional rights, could not be given retroactive effect without impairing vested rights. The motion for reconsideration was denied. The Petition: Plaintiffs appealed, arguing that Article 2264 of the Civil Code of the Philippines, which grants successional rights to children born before its effectivity, should apply. They invoked the provision that such rights shall also be acquired by children born before its effectivity, subject to the qualification in Article 2253 that new rights do not prejudice vested or acquired rights.
Issue(s)
Whether the successional rights granted to adulterous children under the Civil Code of the Philippines can be given retroactive effect to prejudice vested rights acquired under the Civil Code of Spain. Whether the obligation to support minor illegitimate children is extinguished upon the death of the obligor or is transmitted to his heirs.
Ruling
The order of dismissal is reversed, and the case is remanded to the lower court for further proceedings. The plaintiffs are not entitled to share in the estate as heirs but may have a cause of action for support.
Ratio Decidendi
On the issue of successional rights: The Court held that the successional rights granted to adulterous children by the Civil Code of the Philippines cannot be given retroactive effect. When Teofilo Mejia died in 1942, the Civil Code of Spain was in force, and under that law, adulterous children were only entitled to support. The new Civil Code of the Philippines, enacted later, grants certain successional rights to such children. However, Article 2253 of the new Civil Code explicitly states that if a right is declared for the first time, it shall be effective at once, provided it does not prejudice any vested or acquired right. In this case, the heirs of Teofilo Mejia acquired vested rights to his estate under the Civil Code of Spain at the time of his death. Allowing the plaintiffs to claim successional rights under the new Civil Code would impair these vested rights. Therefore, the complaint does not state sufficient facts to constitute a cause of action for partition or recovery of shares in the estate. On the issue of the obligation to support: The Court ruled that while the general rule under Article 150 of the Civil Code of Spain is that the obligation to support ceases upon the death of the obligor, this rule is subject to an exception found in Article 845 of the same Code. Article 845 provides that the obligation to support illegitimate children who are not natural children shall be transmitted to the heirs and shall continue until such children attain their majority or, if incapacitated, while their incapacity lasts. The complaint alleged that some of the plaintiffs were minors at the time of their father's death in 1942. Therefore, assuming the allegations are true, those minor plaintiffs had a cause of action against the defendant, not for partition, but for the enforcement of their right to support, which obligation was transmitted to the heirs.
Main Doctrine
Successional rights granted to adulterous children by the Civil Code of the Philippines cannot be given retroactive effect to impair vested rights acquired under the Civil Code of Spain at the time of the decedent's death. However, the obligation to support minor illegitimate children is transmitted to the heirs.