In the case of Charles Gotardo v. Divina Buling, the Supreme Court affirmed the Court of Appeals’ decision, compelling Charles Gotardo to legally recognize and financially support his minor son, Gliffze Buling. The ruling underscores that when a woman presents a credible claim, supported by evidence, that a man is the father of her child, the burden shifts to the man to disprove paternity. This decision highlights the importance of consistent testimony and the challenges of overturning a lower court’s factual findings, especially in cases involving paternity and child support.

Love, Lies, and Fatherhood: When a Promise Fades

Divina Buling filed a complaint for compulsory recognition and support against Charles Gotardo, claiming he was the father of her child, Gliffze. Charles denied paternity, leading to a trial where Divina testified about their relationship, which began in December 1992. She recounted how Charles courted her, their intimate relations, and his initial happiness upon learning of her pregnancy, including plans for marriage that were later abandoned. Divina presented evidence of their relationship, but the Regional Trial Court (RTC) dismissed her complaint, citing inconsistencies in her testimony and ordering her to return the support she had received during the case’s pendency.

The Court of Appeals (CA) reversed the RTC’s decision, finding that any inconsistencies in Divina’s testimony were minor and satisfactorily explained. The CA emphasized that Charles and Divina had a sexual relationship before August 1994, and that Divina had only been with Charles during that period. The CA ordered Charles to recognize Gliffze as his son and reinstated the order for monthly child support. Charles then elevated the case to the Supreme Court, arguing that the CA erred in its assessment of Divina’s testimony and that the evidence was insufficient to prove paternity.

The Supreme Court upheld the CA’s decision, emphasizing that in paternity cases, the burden of proof lies with the person alleging paternity. The Court explained that filiation can be established through various means, including birth records, judicial admissions, or other admissible evidence. The Court cited Herrera v. Alba, which outlines the procedural aspects of a paternity action, including establishing a prima facie case and the available affirmative defenses.

According to Herrera v. Alba, G.R. No. 171713, December 17, 2007, 540 SCRA 480, 490:

“[F]iliation proceedings are usually filed not just to adjudicate paternity but also to secure a legal right associated with paternity, such as citizenship, support (as in this case) or inheritance. [In paternity cases, the burden of proof] is on the person who alleges that the putative father is the biological father of the child.”

The Court found that Divina had established a prima facie case by testifying that she had been sexually involved only with Charles at the time of conception. Rodulfo Lopez corroborated her testimony regarding their intimate relationship. Charles, on the other hand, did not deny having sexual encounters with Divina but claimed they occurred later than she asserted, making it physically impossible for her to be three months pregnant in September 1994, when he was informed of the pregnancy. However, Charles failed to substantiate his allegations of infidelity or promiscuity on Divina’s part.

The Supreme Court addressed the alleged inconsistencies in Divina’s testimony, noting that they were more apparent than real and had been satisfactorily explained. The Court emphasized that a witness’s testimony should be considered in its entirety, rather than in isolated parts. The Court cited Northwest Airlines, Inc. v. Chiong, G.R. No. 155550, January 31, 2008, 543 SCRA 308, 324, which states:

“In ascertaining the facts established by a witness, everything stated by him on direct, cross and redirect examinations must be calibrated and considered.”

The Court found that the totality of Divina’s testimony consistently showed that she had intimate sexual relations with Charles in September 1993. Since filiation was established, the Court affirmed that support is a legal obligation of a parent to their child, whether legitimate or illegitimate, as stipulated in Article 195 of the Family Code of the Philippines.

Article 194 of the Family Code of the Philippines defines support:

“Support comprises everything indispensable for sustenance, dwelling, clothing, medical attendance, education and transportation, in keeping with the financial capacity of the family.”

The Court also noted that the amount of support is variable and depends on the resources of the giver and the necessities of the recipient. It can be adjusted based on changes in the recipient’s needs and the giver’s financial capacity, as specified in Articles 201 and 202 of the Family Code. In this case, the Court sustained the award of P2,000.00 monthly child support, without prejudice to filing a proper motion in the RTC for determining any support in arrears, considering the child’s needs during the case’s pendency.

This case reinforces the principle that once paternity is established, the legal obligation to provide support is undeniable. It clarifies how courts assess witness credibility and the types of evidence considered in paternity cases. The ruling serves as a guide for similar cases, emphasizing the importance of presenting a credible claim of paternity and the challenges of disproving it. The decision protects the rights of children to receive support from their parents, ensuring they have the means necessary for their well-being and development.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals erred in reversing the trial court’s decision and ordering Charles Gotardo to recognize and support his minor son, Gliffze Buling. This revolved around establishing paternity and the credibility of the evidence presented.
What evidence did Divina Buling present to prove paternity?	Divina presented her testimony about her relationship with Charles, including their intimate relations and his initial plans to marry her. She also presented corroborative testimony from Rodulfo Lopez, who confirmed their relationship.
What was Charles Gotardo’s defense?	Charles denied paternity, claiming that his sexual encounters with Divina occurred later than she claimed, making it impossible for him to be the father. He also implied infidelity on Divina’s part but failed to provide any evidence.
How did the Supreme Court address the inconsistencies in Divina’s testimony?	The Supreme Court found that the inconsistencies were minor and satisfactorily explained, noting that a witness’s testimony should be considered in its entirety. The Court determined there was no real inconsistency and the totality of Divina’s testimony was consistent.
What is the legal basis for child support in the Philippines?	Article 195 of the Family Code of the Philippines establishes the legal obligation of parents to support their children, whether legitimate or illegitimate. Support includes everything indispensable for sustenance, dwelling, clothing, medical attendance, education, and transportation.
How is the amount of child support determined?	The amount of support is determined based on the financial capacity of the giver and the needs of the recipient, and can be adjusted based on changes in these factors, as outlined in Articles 201 and 202 of the Family Code.
What is a prima facie case in a paternity action?	A prima facie case exists when a woman declares, supported by corroborative proof, that she had sexual relations with the putative father. At this point, the burden of evidence shifts to the putative father to disprove paternity.
What affirmative defenses are available to a man in a paternity action?	The two affirmative defenses available are (1) incapability of sexual relations with the mother due to physical absence or impotency, or (2) that the mother had sexual relations with other men at the time of conception.

The Supreme Court’s decision underscores the importance of establishing paternity to secure a child’s right to support. This case provides valuable guidance on the types of evidence that can be used to prove paternity and the challenges of disproving it, ultimately ensuring that children receive the financial support they need for their well-being and development.

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: Gotardo v. Buling, G.R. No. 165166, August 15, 2012