Nabong v. Alonso
REITERATIONFacts
The Antecedents: Paz Nabong, single, and Eligio Alonso, single, cohabited from 1930 to September 1932. During this period, two children were born: Valentino Jesus Alonso on April 16, 1931, and Eugenio Alonso on June 2, 1932. Eligio Alonso subscribed to the birth certificates of both children, acknowledging them as his illegitimate children and giving them his surname. He had Valentino baptized, selected godparents, and provided for the support of the children and Paz Nabong until he abandoned Paz Nabong to marry another woman. Procedural History: The Court of First Instance of Manila ordered the defendant, Eligio Alonso, to provide monthly support of at least P20 for each child until they reach the age of majority or become self-supporting. The court also declared Valentino Jesus Alonso and Eugenio Alonso as recognized natural children of the defendant, with all attendant rights and privileges, and ordered the defendant to pay costs. The Petition: The defendant, Eligio Alonso, appealed the decision of the trial court, assigning four alleged errors.
Issue(s)
Whether the defendant-appellant may be compelled to acknowledge the minors Valentino Jesus Alonso and Eugenio Alonso as his natural children. Whether the amount of monthly support granted to the minors is reasonable.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance in toto, ordering the defendant to provide support for his two children and declaring them as recognized natural children, with costs to the appellant.
Ratio Decidendi
On the issue of compelling acknowledgment of natural children: The Court held that the defendant-appellant may be compelled to acknowledge the minors as his natural children. This is based on the provisions of Article 135, case 2, of the Civil Code. The evidence presented, including the birth certificates where the defendant acknowledged paternity, his act of having the children baptized, selecting their godparents, giving them his surname, presenting them to his parents as his own, and providing for their support, conclusively established that the children were in the uninterrupted possession of the status of natural children of the defendant. These direct acts by the defendant justified the compulsion of acknowledgment. The Court cited jurisprudence wherein similar acts, such as stating to the attending physician that he is the father, living maritally with the mother and child, presenting the child as his own, and providing support and affection, were deemed unequivocal acts of a real father, establishing the status of a natural child. On the reasonableness of the allowance for support: The Court found the amount of allowance granted by the lower court to the minors to be reasonable. No specific reasoning is detailed beyond this affirmation, implying that the trial court's assessment was deemed sufficient and not erroneous.
Main Doctrine
The uninterrupted possession of the status of natural children, justified by the father's direct acts, compels acknowledgment under Article 135 of the Civil Code.