FACTS:
Carmen Quimiguing filed a case to compel Felix Icao to recognize her as his illegitimate child and to provide support.
She presented documentary evidence, including letters allegedly written by Icao, to prove filiation.
The trial court dismissed the complaint, holding that there was insufficient evidence to establish filiation under the Civil Code.
On appeal, the issue was elevated to the Supreme Court.
ISSUE:
Can filiation be proved by private handwritten documents (letters) acknowledging the child, even if they are not public documents or official records?
RULING:
Yes. Filiation may be proved by private handwritten documents, provided they clearly acknowledge the child.
REASONING:
Under Article 278 of the Civil Code (now Article 172 of the Family Code), filiation of illegitimate children may be proved by:
1. The record of birth,
2. A will,
3. A statement before a court of record, or
4. Any authentic writing of the parent.
The term “authentic writing” includes private handwritten documents of the parent acknowledging the child, even if not notarized.
In this case, the letters written by Felix Icao to Carmen’s mother were clear acknowledgments of paternity.
The Court stressed that what is important is the clear and unmistakable recognition of the child by the parent, not the formality of the document.
DOCTRINE:
Filiation of an illegitimate child may be established by private handwritten documents of the parent acknowledging the child, even if not notarized.