Perla v. Baring (G.R. No. 172471; November 12, 2012)

CASE DIGEST: ANTONIO PERLA v. MIRASOL BARING and RANDY PERLA
FACTS: Respondent Mirasol Baring (Mirasol) and petitioner Antonio Perla (Antonio) were allegedly neighbors. Eventually, they became sweethearts. When Mirasol became pregnant, Antonio allegedly assured her that he would support her. However, Antonio started to evade her.

Mirasol and her then minor son, Randy Perla (Randy), filed before the RTC a Complaint for support against Antonio. Mirasol and Randy thus prayed that Antonio be ordered to support Randy. During the trial, Mirasol presented Randys Certificate of Live Birth and Baptismal Certificate indicating her and Antonio as parents of the child. Mirasol testified that she and Antonio supplied the information in the said certificates. The RTC rendered a decision ordering Antonio to support Randy, which was affirmed by CA.

ISSUE: Is Randy entitled for support from Antonio?

HELD: Mirasol and Randy's Complaint for support is based on Randy's alleged illegitimate filiation to Antonio. Hence, for Randy to be entitled for support, his filiation must be established with sufficient certainty. The Court has ruled that a high standard of proof is required to establish paternity and filiation. An order for x xx support may create an unwholesome situation or may be an irritant to the family or the lives of the parties so that it must be issued only if paternity or filiation is established by clear and convincing evidence.In the case at bar, Mirasol and Randy failed to establish Randys illegitimate filiation to Antonio. The Certificate of Live Birth and baptismal certificate of Randy have no probative value to establish Randys filiation to Antonio since the latter had not signed the same. A certificate of live birth purportedly identifying the putative father is not competent evidence of paternity when there is no showing that the putative father had a hand in the preparation of said certificate. Also, while a baptismal certificate may be considered a public document, it can only serve as evidence of the administration of the sacrament on the date specified but not the veracity of the entries with respect to the child's paternity. Thus, x xx baptismal certificates are per se inadmissible in evidence as proof of filiation and they cannot be admitted indirectly as circumstantial evidence to prove the same.

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Generally, factual findings of trial courts, when affirmed by the CA, are binding on the Court. However, this rule admits of certain exceptions such as when the finding is grounded entirely on speculations, surmises or conjectures or when the judgment of the CA is based on misapprehension of facts. As this case falls under these exceptions, the Court is constrained to re-examine the factual findings of the lower courts. GRANTED.

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