Cruz v. Castillo
REITERATIONFacts
The Antecedents: Plaintiff Belen Cruz, a former housemaid, filed a complaint against defendant Exequiel Castillo for compulsory recognition and support of their child, Anselma Armi Castillo. Plaintiff alleged that she lived in the defendant's mother's house where the defendant also resided. She claimed that on October 5, 1959, the defendant forced her into sexual intercourse, and subsequent sexual relations occurred on October 12, 21, and 23, 1959. Plaintiff gave birth to Anselma Armi Castillo on July 11, 1960. The child was named after the defendant's mother. Plaintiff alleged she was driven away by the defendant's mother upon noticing her pregnancy. She further stated that the defendant refused to provide support, forcing her to sell goods in the market to maintain the child. She also noted the defendant's current marital status and ownership of a store, car, and television set. Procedural History: The Court of First Instance of Nueva Ecija rendered a decision on July 27, 1964, finding the defendant to be the father of the child, ordering him to provide P30.00 monthly support from the filing of the complaint, and to pay P300.00 as attorney's fees. The Petition: Defendant appealed the decision to the Court of Appeals, which certified the case to the Supreme Court as it involved only questions of law. The appellant admitted paternity but contested the commencement date of the support obligation.
Issue(s)
Whether the lower court erred in ordering the defendant to give support to the child from the date of the filing of the complaint. Whether the lower court erred in declaring the defendant as the father of the natural child based on physical resemblance.
Ruling
The appealed judgment is modified. The defendant is declared the natural child of Exequiel Castillo, ordered to recognize the child as his natural child, and to provide support in the amount of P100.00 per month from July 27, 1964. The defendant is also ordered to pay P500.00 as attorney's fees.
Ratio Decidendi
On Issue 1: The Supreme Court modified the lower court's ruling regarding the commencement of support. The Court held that a natural child not recognized by the father has no rights, including the right to support. The obligation to support arises only upon recognition, whether voluntary or compulsory, which grants the child the rights of support and succession. In this case, since the father had not voluntarily recognized the child, his obligation to support commenced only after the judgment compelling recognition was rendered by the lower court. Therefore, support should begin from July 27, 1964, the date of the lower court's decision, not from the filing of the complaint. On Issue 2: The Supreme Court found the contention regarding physical resemblance to be unmeritorious. The Court noted that the finding of resemblance was a minor point and was not even mentioned in the trial court's conclusion. More importantly, the appellant admitted paternity in his brief. The Court reiterated the principle that once paternity is established by evidence and no longer disputed by the father, he should be compelled to recognize the child as his own. The appealed judgment merely declared paternity, and the Supreme Court affirmed this aspect while modifying the support order.
Main Doctrine
A natural child not recognized by the father has no rights whatsoever, not even to support. The obligation to support arises only upon recognition, whether voluntary or compulsory, which gives the natural child the rights of support and succession.