Aruego v. Court of Appeals

G.R. No. 112193 (March 13, 1996)

Facts:

On March 7, 1983, a complaint for Compulsory Recognition and Enforcement of Successional Rights was filed in the Regional Trial Court of Manila by minors Antonia F. Aruego and Evelyn F. Aruego, represented by their mother Luz M. Fabian. The defendants included Jose E. Aruego, Jr. and the five minor children of the deceased Gloria A. Torres, represented by their father Justo P. Torres, Jr. The complaint alleged that the late Jose M. Aruego, Sr., a married man, had an extramarital relationship with Luz M. Fabian from 1959 until his death on March 30, 1982. Antonia and Evelyn were born from this relationship, and the complaint sought to declare them as illegitimate children of Jose M. Aruego, Sr., compel the defendants to recognize them as heirs, and determine their share in the estate.

The plaintiffs claimed that Jose M. Aruego, Sr. had acknowledged them as his children through various means, including financial support, use of his surname, and social recognition. The petitioners denied these allegations. After trial, the lower court ruled in favor of Antonia, declaring her as the illegitimate daughter of Jose M. Aruego, Sr., while ruling that Evelyn was not. The court ordered the defendants to recognize Antonia and deliver her share of the estate.

The petitioners filed a motion for partial reconsideration, arguing that the trial court lost jurisdiction due to the enactment of the Family Code, which they claimed barred the action for compulsory recognition since it must be filed during the lifetime of the alleged parent. The trial court denied the motion, and the petitioners' subsequent appeal was dismissed for being filed out of time. They then filed a petition for prohibition and certiorari with the Court of Appeals, which was also dismissed.

Legal Issues:

1. Should the provisions of the Family Code be applied to the case, given that the complaint was filed before its enactment?
2. Will the application of the Family Code retroactively affect the vested rights of the private respondent?
3. Did the trial court lose jurisdiction over the case due to the passage of the Family Code?

Arguments:

• Petitioners' Arguments:

  • The petitioners contended that the Family Code, effective August 3, 1988, superseded the Civil Code provisions regarding the recognition of illegitimate children. They argued that under the Family Code, an action for compulsory recognition based on open and continuous possession of the status of an illegitimate child must be filed during the lifetime of the alleged parent, without exceptions. Since the complaint was filed after the death of Jose M. Aruego, Sr., they claimed the action had prescribed.
  • They also argued that the Family Code should apply retroactively, as it does not prejudice vested rights.

• Respondents' Arguments:

  • The respondents maintained that their action was valid under the Civil Code, as it was filed before the Family Code took effect. They argued that the right to file the action was vested upon the filing of the complaint, and thus, the provisions of the Family Code should not apply retroactively to their detriment.
  • They cited previous jurisprudence indicating that the filing of a complaint under the Civil Code vested their rights, which could not be impaired by subsequent legislation.

Court's Decision and Legal Reasoning:

The Supreme Court ruled in favor of the respondents, affirming the decision of the Court of Appeals. The Court held that the action for compulsory recognition filed by Antonia Aruego was governed by Article 285 of the Civil Code, as it was filed prior to the enactment of the Family Code. The Court emphasized that the right to file the action was vested upon the filing of the complaint, and applying the Family Code retroactively would adversely affect this right.

The Court further clarified that the trial court retained jurisdiction over the case despite the passage of the Family Code, as jurisdiction once attached cannot be ousted by subsequent events. The Court also noted that the action was not barred by prescription, as the complaint was filed while Antonia was still a minor, which is an exception under the Civil Code.

Significant Legal Principles Established:

1. The principle that the jurisdiction of a court, once attached, cannot be ousted by subsequent events or changes in law.
2. The recognition that rights vested by the filing of a complaint under the Civil Code cannot be impaired by the enactment of the Family Code.
3. The distinction between the provisions of the Civil Code and the Family Code regarding the recognition of illegitimate children, particularly concerning the timing of filing actions based on the status of the alleged parent.