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Certificate and the Marriage Contract of Leopoldo, which merely stated that Natalia 7. In this case, the courts below did not appreciate any other material proof
is his mother, are inadequate to prove his filiation with the property owner related to the baptismal certificate of Leopoldo that would establish his
In resolving the issue of Filiation, the RTC and the CA referred to Articles 172 1 and 1752 of filiation with Natalia, whether as a legitimate or as an illegitimate son.
the Family Code. 8. The only other document considered by the RTC and the CA was the
1. The parties concede that there is no record of Leopoldo's birth in either the NSO Marriage Contract of Leopoldo. But, like his baptismal certificate, his
or in the Office of the Municipal Registrar of Kalibo, Aklan. Marriage Contract also lacks probative value as the latter was prepared
2. The RTC and the CA then referred to other means to prove the status of without the participation of Natalia.
Leopoldo: his Certificate of Baptism and his Marriage Contract. Since both 9. The instant case is similar to an issue raised in Paa v. Chan. The claimant in
documents indicate Natalia as the mother of Leopoldo, the courts a quo that case relied upon baptismal and marriage certificates to argue filiation.
concluded that respondent heirs of Leopoldo had sufficiently proven the filiation The Court said:
of their ancestor to the original owner. a. As regards the baptismal and marriage certificates of Leoncio
3. For this reason, the RTC and the CA maintained that the heirs of Leopoldo are Chan, the same are not competent evidence to prove that he was
entitled to an equal share of the property, together with the heirs of Gilberto and the illegitimate child of Bartola Maglaya by a Chinese father. While
heirs of Silvela. these certificates may be considered public documents, they
4. Jurisprudence has already assessed the probative value of baptismal are evidence only to prove the administration of the
certificates. In Fernandez v. Court of Appeals, which referred to our earlier sacraments on the dates therein specified — which in this case
rulings in Berciles v. Government Service Insurance System and were the baptism and marriage, respectively, of Leoncio Chan —
Macadangdang v. Court of Appeals, the Court explained that because the but not the veracity of the statements or declarations made
putative parent has no hand in the preparation of a baptismal certificate, therein with respect to his kinsfolk and/or citizenship.
that document has scant evidentiary value. 10. The Baptismal Certificate and the Marriage Contract of Leopoldo, which
5. The canonical certificate is simply a proof of the act to which the priest may merely stated that Natalia is his mother, are inadequate to prove his
certify, i.e., the administration of the sacrament. In other words, a baptismal filiation with the property owner. Moreover, by virtue of these documents
certificate is "no proof of the declarations in the record with respect to the alone, the RTC and the CA could not have justly concluded that Leopoldo
parentage of the child baptized, or of prior and distinct facts which require and his successors-in-interest were entitled to a one-third share of the
separate and concrete evidence." property left by Natalia, equal to that of each of her undisputed legitimate
6. In cases that followed Fernandez, we reiterated that a baptismal certificate is children — Gilberto and Silvela.
insufficient to prove filiation. But in Makati Shangri-La Hotel and Resort, Inc. 11. As held in Board of Commissioners v. Dela Rosa, a baptismal certificate is
v. Harper, this Court clarified that a baptismal certificate has evidentiary certainly not proof of the status of legitimacy or illegitimacy of the claimant.
value to prove kinship "if considered alongside other evidence of filiation." Therefore, the CA erred in presuming the hereditary rights of Leopoldo
Therefore, to resolve one's lineage, courts must peruse other pieces of evidence to be equal to those of the legitimate heirs of Natalia.
instead of relying only on a canonical record. By way of example, we have
considered the combination of testimonial evidence, family pictures, as DISPOSITION:
well as family books or charts, alongside the baptismal certificates of the WHEREFORE, the Petition for Review on Certiorari filed by petitioner heirs of Gilberto Roldan is
PARTIALLY GRANTED. The Court of Appeals Decision and Resolution in CA-G.R. CEB-CV No. 02327
claimants, in proving kinship.
are hereby MODIFIED to read as follows:
1. Only the heirs of Gilberto Roldan and Silvela Roldan are declared co- owners of the land
1 covered by Original Certificate of Title No. P-7711, which should be partitioned among them
Art. 172. The filiation of legitimate children is established by any of the following:
in the following proportions:
(1) The record of birth appearing in the civil register or a final judgment; or
(2) An admission of legitimate filiation in a public document or a private handwritten instrument and signed by the parent
a. One-half share to the heirs of Gilberto Roldan; and
concerned. b. One-half share to the heirs of Silvela Roldan.
In the absence of the foregoing evidence, the legitimate filiation shall be proved by:
(1) The open and continuous possession of the status of a legitimate child; or
2. Petitioners are ordered to account for and deliver to the heirs of Silvela Roldan their one-half
(2) Any other means allowed by the Rules of Court and special laws. share on the produce of the land.
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Art. 175. Illegitimate children may establish their illegitimate filiation in the same way and on the same evidence as legitimate
children.
The action must be brought within the same period specified in Article 173, except when the action is based on the second
paragraph of Article 172, in which case the action may be brought during the lifetime of the alleged parent.