Heirs Of Pedro Cabais Et. Al., Vs.

The Honorable Court Of Appeals, Constancia Paglinawan, et al. G.R. No.

106314-15 October 8, 1999,
xxx
x x x On the contrary, a baptismal certificate, a private document, which, being
hearsay, is not a conclusive proof of filiation.  It does not have the same
probative value as a record of birth, an official or public document. 
 In US vs. Evangelista, this Court held that church registers of births,
marriages, and deaths made subsequent to the promulgation of General Orders
No. 68 and the passage of Act No. 190,  are no longer public writings, nor are
they kept by duly authorized public officials.  Thus, in this jurisdiction, a certificate
of baptism such as the one herein under controversy is no longer regarded with
the same evidentiary value as official records of birth. Moreover, on this score,
jurisprudence is consistent and uniform in ruling that the canonical certificate of
baptism is not sufficient to prove recognition. 
The unjustified failure to present the birth certificate instead of the
baptismal certificate now under consideration or to otherwise prove filiation by
any of the means recognized by law weigh heavily against respondents.
In Macadangdang vs. Court of Appeals, et al.,  this Court declared that a
baptismal certificate is evidence only to prove the administration of the
sacrament on the dates therein specified, but not the veracity of the declarations
therein stated with respect to his kinsfolk. The same is conclusive only of the
baptism administered, according to the rites of the Catholic Church, by the priest
who baptized subject child, but it does not prove the veracity of the declarations
and statements contained in the certificate concerning the relationship of the
person baptized.  It is indispensable that such declarations and statements are
shown by proof recognized by law.
------------------------------------x

Church registries of births, marriages, and deaths made subsequent to the

promulgation of General Orders No. 68, promulgated on December 18, 1889,
and the passage of Act No. 190, enacted on August 7, 1901, are no longer public
writings, nor are they kept by duly authorized public officials. They are private
writings and their authenticity must, therefore, be proved, as are all other private
writings in accordance with the Rules of Evidence citing Llemos v. Llemos, G.R.
No. 150162, 2007)
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Intestate Estate Of Deceased Natividad Pareja, Paz Pareja

Vs.Julio Pareja, Regina Pareja, And Jose Pareja Oppositors-Appellees, Soledad
Pareja Marcial, G.R. No. L-5824, May 31, 1954
X x x Neither are the baptismal certificates x x x public documents or
public writings, because the parochial records of baptisms are not public or
official records, as they are not kept by public officers, and are no proof of
relationship or filiation of the child baptized.

-----------------------------------x
The rules for establishing filiation are found in Articles 172 and 175 of the Family
Code which provide as follows:

Article 172. The filiation of legitimate children is established by any of the

following:

(1) The record of birth appearing in the civil register or a final judgment; or

(2) An admission of legitimate filiation in a public document or a private

handwritten instrument and signed by the parent concerned.

In the absence of the foregoing evidence, the legitimate filiation shall be proved
by:

(1) The open and continuous possession of the status of a legitimate child;
or

(2) Any other means allowed by the Rules of Court and special laws.

Xxx
As Cited In The Case Of Heirs Of Paula C. Fabillar, As Represented By
Aureo[[*]] Fabillar,  Vs. Miguel M. Paller, Florentina P. Abayan, And Demetria P.
Sagales, January 21, 2019, G.R. No. 231459

X x x In the absence of the record of birth and admission of legitimate filiation,

Article 172 of the Family Code (Code) provides that filiation shall be proved by
any other means allowed by the Rules of Court and special laws. Such other
proof of one's filiation may be a baptismal certificate, a judicial admission, a
family Bible in which his name has been entered, common reputation respecting
his pedigree, admission by silence, the testimonies of witnesses, and other kinds
of proof admissible under Rule 130 of the Rules of Court (Rules). 51 Article
17552 of the same Code also allows illegitimate children to establish their filiation
in the same way and on the same evidence as that of legitimate children.

However, it is jurisprudentially settled that a baptismal certificate has

evidentiary value to prove filiation only if considered alongside other
evidence of filiation. Because the putative parent has no hand in the
preparation of a baptismal certificate, the same has scant evidentiary value if
taken in isolation; while it 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." As such, a
baptismal certificate alone is not sufficient to resolve a disputed filiation, and the
courts must peruse other pieces of evidence instead of relying only on a
canonical record.