Inconclusive proof

Is the baptismal certificate a conclusive proof of parentage, or more specifically, of daughter-mother relationship? This is the issue raised in this case involving a parcel of land with an area of 1,638 sq. meters.

This land was originally registered in the name of Celia, the mother of Fely. Fely was married   and had an only son Mario. She died ahead of her mother Celia thus leaving Mario as the only legal heir of his grandmother Celia by right of representation. So when Celia died, Mario executed a Deed of Self Adjudication, adjudicating in his favor the subject land. By virtue thereof the Original Certificate in the name of Celia was cancelled and in lieu thereof, a Transfer Certificate of Title (TCT) was issued in Mario’s name.

Shortly thereafter, the heirs of the other relatives of Celia filed a complaint for partition and accounting against Mario claiming that the TCT issued in his name was in derogation of their inheritance rights. While this case was pending, Mario died. So this other group claiming rights to the land as heirs of Celia just entered the property in dispute, constructed houses thereon, and did not pursue anymore their complaint, which was thus dismissed.

As a consequence, the heirs of Mario filed a complaint for quieting of title, recovery of possession and ownership against this group claiming inheritance rights over the property. The lower court initially ruled in favor of the heirs of Mario, quieting their title, ordering the other claimants-heirs to turn over possession of the lot and pay the rents.

But subsequently the lower court granted the motion for reconsideration of the other claimants and thus ruled in their favor. The court said that based on the Baptismal Certificate of Fely, Mario’s mother, she was not the daughter of Celia, the original owner of the lot. So her son Mario’s title to the property was fraudulently obtained. Was the lower court correct?

No. A baptismal certificate is not a conclusive proof that Mario’s mother Fely is not the daughter of Celia who originally owned the lot in question. It is a private document which, being hearsay, does not have the same probative value as a record of birth, an official or public document. 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 concerning the relationship of the person baptized. So the lower court is not correct in relying on the baptismal certificate in question to establish the filiation of Mario’s mother Fely. Its initial decision in favor of Mario’s heirs must be reinstated (Heirs of Pedro Cabais vs. Court of Appeals, GR Nos. 106314-15, October 8, 1999).

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