Aruego vs. Court of Appeals

An action for compulsory recognition of an illegitimate child, filed under the Civil Code before the effectivity of the Family Code, vests a right of action that cannot be impaired by the retroactive application of the Family Code's prescriptive periods; thus, the trial court retains jurisdiction and must adjudicate the case under the prior law.

Private respondent Antonia Aruego, a minor represented by her mother Luz Fabian, filed a complaint for compulsory recognition and enforcement of successional rights against the legitimate heirs of the deceased Jose M. Aruego, Sr. She alleged she was his illegitimate child, born of an amorous relationship, and based her claim on her "open and continuous possession of the status of an illegitimate child." The complaint was filed on March 7, 1983, almost a year after the putative father's death on March 30, 1982.

• Nature of the Action: A complaint for compulsory recognition and enforcement of successional rights was filed by private respondent Antonia Aruego, as an alleged illegitimate child of the deceased Jose M. Aruego, Sr., against his legitimate heirs (petitioners).
• Basis of Claim: The complaint anchored the claim on "open and continuous possession of the status of an illegitimate child," citing acts of paternal support, use of surname, and public acknowledgment.
• Lower Court Judgment: The RTC ruled in favor of private respondent, declaring her an illegitimate daughter and ordering her recognition and inheritance share.
• Procedural Challenge: After the Family Code took effect on August 3, 1988, petitioners argued the trial court lost jurisdiction because, under Article 175 of the Family Code, an action based on continuous possession of status must be brought during the alleged parent's lifetime. Since the father died before the complaint was filed, the action had prescribed.
• Vested Right Argument: The Supreme Court, applying precedent, held that the filing of the complaint under the Civil Code regime vested a right of action. Article 285 of the Civil Code allowed such an action to be filed after the parent's death if the child was still a minor, which was the case here.

• Prescription under Family Code: Petitioners argued that under Article 175, paragraph 2 of the Family Code, an action for compulsory recognition based on "open and continuous possession of status" must be brought during the lifetime of the alleged parent. Since the complaint was filed after the father's death, the action had prescribed.
• Retroactive Application: Petitioners maintained that Article 256 of the Family Code mandates its retroactive effect unless it impairs vested rights. They contended that private respondent had no vested right to file the action after the father's death under the new law, so the Family Code should apply and bar the claim.
• Jurisdictional Defect: Petitioners asserted that the trial court lost jurisdiction to proceed with the case after the Family Code's effectivity, as the new law eliminated the exception that previously allowed a minor to file the action within four years of reaching majority after the parent's death.

• Vested Right Under Civil Code: Respondent countered that the right of action vested upon the filing of the complaint under the Civil Code, which permitted the action to be filed after the father's death because the child was a minor. This vested right could not be impaired by the retroactive application of the Family Code.
• Jurisdictional Attachment: Respondent argued that the trial court acquired jurisdiction when the complaint was filed in 1983. Jurisdiction, once attached, is not lost by subsequent changes in the law or facts that would have prevented jurisdiction from initially attaching.
• Precedent Control: Respondent relied on the Supreme Court's ruling in Tayag v. Court of Appeals, which held in a similar case that the filing of the complaint under the Civil Code vested a right to have the case adjudicated under that law.

• Retroactivity of Family Code: Whether the prescriptive provisions of the Family Code (Article 175) should be applied retroactively to an action for compulsory recognition filed before its effectivity.
• Vested Right: Whether the filing of the complaint under the Civil Code created a vested right that would be impaired by applying the Family Code's prescriptive rule.
• Jurisdiction: Whether the trial court lost jurisdiction over the case after the Family Code took effect.

• Retroactivity of Family Code: The Family Code's prescriptive provisions cannot be applied retroactively to this case because doing so would prejudice the vested right of action that accrued to private respondent upon filing her complaint under the Civil Code. Article 256 of the Family Code prohibits retroactive application that impairs vested rights.
• Vested Right: The right of action was vested by the filing of the complaint under the Civil Code regime. Under Article 285 of the Civil Code, an action for recognition could be filed after the parent's death if the child was a minor, which private respondent was. This right could not be taken away by the subsequent enactment of the Family Code.
• Jurisdiction: The trial court acquired jurisdiction when the complaint was filed in 1983. Jurisdiction, once acquired, continues until the case is finally disposed of, regardless of subsequent changes in the law that might have prevented jurisdiction from attaching initially.

• Vested Right Doctrine — A right is vested when it is already complete and consummate, and is no longer open to doubt. The filing of a complaint under a prevailing law vests the right to have the case adjudicated under that law. A subsequent law cannot impair this right if its retroactive application would prejudice the vested right.
• Jurisdictional Attachment — The jurisdiction of a court, once it has attached, cannot be ousted by subsequent happenings or events, even if those events are of a character that would have prevented jurisdiction from attaching in the first instance. The court retains jurisdiction until it finally disposes of the case.

• "The fact of filing of the petition already vested in the petitioner her right to file it and to have the same proceed to final adjudication in accordance with the law in force at the time, and such right can no longer be prejudiced or impaired by the enactment of a new law." — This passage, adopted from Republic v. Court of Appeals, articulates the core principle that the act of filing under a prior law creates a vested right to adjudication under that law.
• "The jurisdiction of a court, whether in criminal or civil cases, once attached cannot be ousted by subsequent happenings or events, although of a character which would have prevented jurisdiction from attaching in the first instance, and it retains jurisdiction until it finally disposes of the case." — This reaffirms the stability of judicial jurisdiction once established.

• Tayag v. Court of Appeals, 209 SCRA 665 (1992) — Followed as squarely applicable. The Court held that the filing of a complaint for recognition under the Civil Code vested a right of action that could not be barred by the Family Code's retroactive application.
• Republic v. Court of Appeals, 205 SCRA 356 (1992) — Adopted and applied. The ruling that the filing of a petition vests a right to have it adjudicated under the law in force at the time was the foundation for the decision in Tayag and this case.

• Article 285, Civil Code of the Philippines — Provided that an action for recognition of natural children may be brought only during the lifetime of the presumed parents, except if the parent died during the minority of the child, in which case the child may file the action before the expiration of four years from attaining majority. This was the governing law when the complaint was filed.
• Article 175, Family Code of the Philippines — Provides that an action for compulsory recognition based on "open and continuous possession of the status of an illegitimate child" must be brought during the lifetime of the alleged parent. Petitioners argued this superseded Article 285 of the Civil Code.
• Article 256, Family Code of the Philippines — Mandates the Code's retroactive effect unless it prejudices or impairs vested or acquired rights. The Court used this provision to limit the retroactive application of Article 175.

• Justice Teodoro R. Padilla
• Justice Jose A.R. Bellosillo
• Justice Santiago M. Kapunan