Parental claim conflict

DNA (deoxyribonucleic acid) is the genetic material found in most human cells, carrying information that is passed from one generation to the next. The Supreme Court considered its use to establish parentage in the dispute between Maria and Lina.

Maria was married to Ramon and had two children. After her second child, she underwent ligation and could not have more children. She later left Ramon and lived with Carlos in a common law relationship. Carlos was unable to have children due to an accident, and the couple had no children during their many years together. Lina, a laundrywoman, worked for them and had six children. Her youngest, Junjun, was born on April 27, 1989, assisted by midwife Aling Rosa.

One day, Maria asked Lina to leave Junjun in her care. When Lina returned, both Maria and Junjun were gone. Despite repeated searches, Lina could not find him for four years. During this time, her problems with her husband Pedro partially healed as they searched together for their missing child.

Four years later, Lina learned of Carlos’ death and went to his wake in Hagonoy, Bulacan. There she saw a four-year-old boy named Marco, whom Carlos’ brother Daniel claimed was adopted by Maria and Carlos. Lina immediately recognized Marco as her missing son Junjun. She asked Maria to return the child, but Maria refused, leading Lina and Pedro to file a petition for habeas corpus.

During the trial, Lina testified about the child’s birth and disappearance. The court observed strong physical resemblance between Lina and the child. Midwife Aling Rosa confirmed Junjun’s birth, while Daniel testified about Carlos’ sterility and the adoption claim. Maria insisted she was the child’s mother, presenting a birth certificate that was registered four months after the birth and falsely claimed a marriage with Carlos. She did not present a midwife to support her claim.

The court found Lina’s evidence sufficient. Both Maria and Carlos were incapable of having children, Lina presented the midwife and clinical records, and the birth certificate had discrepancies. Physical resemblance between Lina and the child also supported parentage.

The Supreme Court affirmed that Lina was the true mother of Junjun. While DNA testing was not required, the Court recognized its usefulness for future parentage disputes. Courts are encouraged to apply scientifically obtained DNA results to resolve identity and custody issues efficiently (Tijing vs. Court of Appeals, 354 SCRA 17, G.R. No. 125901, March 8, 2001).