Baptismal certificate is not sufficient to prove filiation

Dear PAO,

I have a question regarding the use of my baptismal certificate, which indicates the name of my deceased father. Can I use it to prove filiation? Aside from my baptismal certificate, I don't have any other document to prove my filiation to him. Can you enlighten me on this matter?

Hazel

Dear Hazel,

Article 172 of the Family Code (FC) of the Philippines outlines the ways in which a man may be recognized as the father of a child and provides that paternity may be established through several formal and legally recognized methods. In particular, it provides that:

«Art. 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

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"(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."

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Furthermore, the Supreme Court, in the case of Fabillar v. Paller, GR 231459, Jan. 21, 2019, penned by Associate Justice Estela Perlas-Bernabe, explained:

«In the absence of the record of birth and admission of legitimate filiation, Article 172 of the Family 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. Article 175 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