What is the value of a baptismal certificate as proof of filiation? This is answered in this case of Candido and his heirs.
Candido inherited a parcel of land containing an area of 1,638 square meters from his grandmother Mamerta. He inherited said property by right of representation because his mother Crisanta, only daughter of Mamerta, died ahead of the latter. Candido executed an affidavit of Self Adjudication, adjudicating in his favor the said property. Thus, a new Transfer Certificate of Title was issued in his name.
Shortly after obtaining title thereto, several persons headed by Trinidad who were relatives of Mamerta, the original owner, filed a suit against Candido for partition and accounting claiming to be co-owners of said property he inherited.
During the pendency of said case Candido died. Whereupon, Trinidad and his group entered the property in dispute and constructed houses thereon, depriving the heirs of Candido headed by Consuelo, of the possession thereof. Having thus successfully taken over the possession, Trinidad et.al. found it no longer necessary to prosecute the complaint against the late Candido. So their complaint was dismissed for non-suit.
Since they were deprived of possession of the property of their father Candido, Consuelo et.al. sued Trinidad et.al. for quieting of title, recovery of possession and ownership of said land. Consuelo et.al. alleged that the acts of Trinidad et.al. with regard of the disputed property cast a cloud on their title thereto. Trinidad et.al. on the other hand averred that the Title issued in the name of Candido was fraudulently issued. They said that the baptismal certificate of Candido's late mother, Crisanta, did not show her to be the daughter of Mamerta the original owner of the property from whom Candido inherited the same. It appeared on this baptismal certificate that Crisanta was the daughter of Caridad a sister of Mamerta, and not of Mamerta. Only this baptismal certificate not the birth certificate was presented as proof of Candido's filiation. On the basis of such baptismal certificate, the lower court dismissed the action filed by Consuelo et.al. since according to the court Candido's mother was not the daughter of Mamerta. Said ruling was affirmed by the Court of Appeals. Were the lower court and the Court of Appeals correct?
No. The lower court and the Court of Appeals disregarded the limited evidentiary value of a baptismal certificate vis-a-vis a birth certificate.
A birth certificate, being a public document, offers prima facie evidence of filiation and a high degree of proof is needed to overthrow the presumption of truth contained in such public document. This is pursuant to the rule that entries in official records made in the performance of his duty by a public officer are prima facie evidence of the facts therein stated. The evidentiary nature of such document must, therefore, be sustained in the absence of strong, complete and conclusive proof of its falsity or nullity.
On the contrary, a baptismal certificate, a private document, which, being hearsay, is not a conclusive proof of filiation. It does not have the same probative value as a record of birth, an official or public document.
A certificate of baptism such as the one herein under controversy is no longer regarded with the same evidentiary value as official records of birth. The canonical certificate of baptism is not sufficient to prove recognition. It is evidence only to prove the administration of the sacrament on the dates therein specified, but not the veracity of the declarations therein stated with respect to the kinsfolk of the person baptized.
The unjustified failure to present the birth certificate instead of the baptismal certificate or to otherwise prove filiation by any of the means recognized by law weigh heavily against Trinidad et.al. The lower court erred in giving too much credence in the baptismal certificate of Crisanta to prove that she was the daughter of Caridad and not of Mamerta, the original registered owner of the property under controversy (Heirs of Cabals et.al., vs Court of Appeals, et.al. G.R. No. 106314-15).
Atty. Sison's e-mail address is: sison@ipaglabanmo.org