The Supreme Court’s decision in William Liyao, Jr. v. Juanita Tanhoti-Liyao clarifies that a child born during a valid marriage cannot independently question their legitimacy to claim inheritance from someone other than their legal father. This right to challenge legitimacy rests solely with the husband (legal father) or, in certain cases, his heirs. The ruling emphasizes protecting the sanctity of marriage and the legal presumption of legitimacy, preventing children from choosing their filiation based on potential inheritance benefits.

Family Secrets and Inheritance Battles: When Can Legitimacy Be Challenged?

This case revolves around William Liyao, Jr., who, represented by his mother, Corazon Garcia, sought to be recognized as the illegitimate son of the late William Liyao. He aimed to inherit from the deceased William Liyao, claiming continuous possession and enjoyment of that status during the latter’s lifetime. The respondents, Juanita Tanhoti-Liyao (the deceased’s legal wife) and her children, contested this claim. Central to the legal issue is whether William Liyao, Jr., born during his mother’s existing marriage to Ramon Yulo, could legally challenge his legitimacy and claim filiation with the deceased William Liyao.

The court anchored its decision on Article 255 of the New Civil Code, which presumes children born within a valid marriage as legitimate. This presumption, rooted in natural justice, shields children from the stigma of illegitimacy. The law allows for the presumption of legitimacy to be challenged. Article 255 explicitly states that evidence against legitimacy is admissible only in cases of “physical impossibility of the husband having access to his wife within the first one hundred and twenty days of the three hundred which preceded the birth of the child.” This may be caused by the impotence of the husband; the fact that husband and wife were living separately in such a way that access was not possible; or by the serious illness of the husband.

The court stressed that the right to impugn the legitimacy of a child is primarily personal to the husband, as he bears the brunt of scandal resulting from infidelity. Article 262 of the Civil Code outlines specific conditions under which his heirs can exercise this right. The Supreme Court emphasized, “It is only in exceptional cases that his heirs are allowed to contest such legitimacy. Outside of these cases, none – even his heirs – can impugn legitimacy; that would amount to an insult to his memory.” Therefore, the action initiated by Corazon Garcia, on behalf of William Liyao, Jr., to compel recognition of filiation was deemed legally untenable, as the right to challenge legitimacy did not belong to them.

Furthermore, the court addressed the petitioner’s argument that his mother’s separation from her legal husband made it physically impossible for them to have relations. Even with a document titled “Contract of Separation” signed by Ramon Yulo presented, the court held this irrelevant, as the right to impugn legitimacy remains vested in the husband or his qualified heirs. As a result, allowing the child to choose filiation based on their own initiative would undermine the legal framework designed to protect marital stability and the rights of the legal father.

The Supreme Court also dismissed the argument that the testimony of Enrique and Bernadette Yulo, the undisputed children of Corazon Garcia and Ramon Yulo, constituted an implicit challenge to legitimacy. The court highlighted that these acts did not amount to an acceptable legal basis to contest the legitimacy of the child. The court asserted that legitimacy can be impugned only in a direct action brought for that purpose, by the proper parties and within the period limited by law.

In its final ruling, the Court opted not to delve into the evidentiary aspects of whether the deceased William Liyao had acknowledged the petitioner as his son, given the procedural impediment. Absent the legal standing to challenge legitimacy, any claims of acknowledgment were deemed irrelevant. As the Court put it, “there is no clear, competent and positive evidence presented by the petitioner that his alleged father had admitted or recognized his paternity.”

FAQs

What was the key issue in this case?	The key issue was whether a child born during a valid marriage can independently challenge their legitimacy to claim inheritance from someone other than their legal father.
Who has the right to challenge the legitimacy of a child born within a marriage?	The right to challenge the legitimacy of a child born within a marriage primarily belongs to the husband (legal father). In specific circumstances, his heirs may also exercise this right.
What evidence is required to challenge the legitimacy of a child?	Article 255 of the New Civil Code allows challenges to legitimacy based on evidence of physical impossibility for the husband to have access to his wife during the conception period.
Can a child choose their own filiation?	No, a child cannot choose their own filiation. The legal framework protects the marital bond, and filiation is determined by the legal presumptions of marriage unless properly challenged by the husband or his heirs.
What is the legal presumption regarding children born during marriage?	The legal presumption is that children born during a valid marriage are legitimate. This presumption is based on principles of natural justice and aims to protect children from the stigma of illegitimacy.
What was the significance of the “Contract of Separation” in this case?	The “Contract of Separation” was deemed irrelevant. The document did not grant the child or his mother the right to challenge legitimacy, which remains the exclusive right of the husband or his qualified heirs.
Can other relatives challenge the legitimacy of a child?	Generally, no. The right to challenge legitimacy is strictly limited to the husband or, in exceptional cases, his heirs.
What happens if the husband doesn’t challenge the legitimacy?	If the husband doesn’t challenge the legitimacy of a child born within the marriage, the child’s status remains fixed, and they cannot claim filiation with another person.

In conclusion, the Supreme Court’s decision underscores the sanctity of marriage and the legal presumption of legitimacy, preventing a child from choosing filiation based on inheritance benefits. This ruling reaffirms that only the husband, or in specific instances, his heirs, possess the right to challenge the legitimacy of a child born within a valid marriage, thereby maintaining the integrity of family relationships under the law.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: William Liyao, Jr. v. Juanita Tanhoti-Liyao, G.R. No. 138961, March 7, 2002