Amurao v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Romeo S. Amurao was sued for support by Romuel Jerome Buenaventura, the offspring of his illicit relations with a 19-year-old college student. Amurao denied paternity and refused to provide support. Procedural History: The parties agreed to a blood-grouping test by the National Bureau of Investigation (NBI) to determine paternity. The agreement stipulated that if the test indicated possible paternity, paternity would be admitted, and the case would proceed only on the issue of the amount of support. If negative, the case would be dismissed. The NBI report stated the child was a 'possible offspring'. Amurao later moved to reconsider the order for the test, which was denied and affirmed by the Supreme Court. A motion for contempt for non-payment of support pendente lite was filed. The trial court, after hearing evidence on the contempt motion, set the main case for trial. Amurao and his counsel failed to appear, leading the court to declare the case submitted for decision. The trial court rendered judgment for the minor, ordering Amurao to pay P500 monthly support. The Court of Appeals affirmed the judgment but increased the support to P1,500 monthly and ordered payment of arrears in support pendente lite. The Petition: Amurao petitioned the Supreme Court, alleging errors in the Court of Appeals' findings regarding admission of paternity, reliance on evidence from the contempt motion hearing, the increase in support, and the application of specific Civil Code articles.
Issue(s)
Whether the petitioner admitted paternity under the terms of the trial court's order dated September 26, 1977. Whether the Court of Appeals erred in upholding the trial court's decision based on evidence presented at the contempt motion hearing. Whether the Court of Appeals erred in increasing the amount of support awarded. Whether the Court of Appeals erred in applying Article 290 of the Civil Code instead of Articles 296 and 297.
Ruling
The petition is denied for lack of merit. The decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of admission of paternity: The Court held that whether the petitioner made an admission of paternity under the terms of the trial court's order dated September 26, 1977, is a finding of fact. The agreement stipulated that if the blood grouping test found the plaintiff to be a 'possible offspring,' paternity would be admitted. The NBI report confirmed the child was a 'possible offspring,' thus triggering the admission of paternity as per the agreement. On the issue of evidence from the contempt motion hearing: The Court found it proper for the trial court to consider evidence presented by the parties at the hearing of the contempt motion as evidence on the merits of the main case. The parties did not need to repeat the presentation of the same evidence. The petitioner's failure to appear at the hearing for the main case constituted a waiver of his right to adduce additional evidence, thereby precluding him from claiming denial of due process. On the issue of increasing the amount of support: The Court reiterated that the determination of the amount of support is a factual issue. The Court of Appeals' increase in support was deemed proper, considering the minor's age and needs, and was sanctioned by the provisions of the Civil Code regarding support. On the issue of applicable Civil Code articles: The Court found no reversible error in the Court of Appeals' decision. The increase in support was considered proper and sanctioned by Articles 290, 296, and 297 of the Civil Code, which govern the obligation and amount of support.
Main Doctrine
A party who agrees to submit to a blood grouping test to determine paternity and to be bound by its results, and subsequently fails to appear at the trial to present further evidence after the test results indicate possible paternity, waives his right to adduce evidence and may not claim denial of due process.