Eugenio Reyes, et al.

Vs.
Librada Mauricio (deceased) Leonida Mauricio

This case involves the filing of complaint of the Librada and her alleged Leonida
Mauricio to the dept. of Agrarian Reform Adjudication Board (DARAB). They want the
annulment of the contract KASUNDUAN between Librada and Eugenio. And they
prayed for the maintenance of the peaceful possession of the land, with damages.

They averred that they are the legal heirs of Godofredo Mauricio who was the lawful
and registered tenant of Eugenio through his predecessors-in-interest.

Petitioner in this case Eugenio alleged that he was the owner of the subject property
(parcel of land) and the title was formerly registered in the name of Eugenios
siblings; that the property was adjudicated to him by virtue of an extrajudicial
settlement among the heirs following the death of his parents.

***He now, among others questions the legal personality of Leonida to file the case.
As Leonida is only a ward(AMPON) of Godofredo Mauricio and Librada Mauricio,
therefore not a legal heir.

The RTC ruled in favor of Mauricio.

On review to CA it issued a resolution regarding the status of Leonida as a legal
heir and allowed her to substitute her mother librada, who died during the
pendency of the case.

ISSUE:
Can petitioner (Eugenio) contest the legal standing - whether heir or not, of the
respondent (Leonida) in a case here involving tenancy relationship and agricultural
land

HELD:
The Court ruled that Eugenio cannot COLLATERALLY ATTACK THE STATUS OF
LEONIDA IN THE INSTANT PETITION.
It is settled law that filiation cannot be collaterally attacked.

The legitimacy of the child cannot be contested by way of defense or as a collateral

issue in another action for a different purpose.
The necessity of an independent action directly impugning the legitimacy is
more clearly expressed in the Mexican code (article 335) which provides:
"The contest of the legitimacy of a child by the husband or his heirs
must be made by proper complaint before the competent court; any
contest made in any other way is void." This principle applies under our Family
Code. Articles 170 and 171 of the code confirm this view, because they refer to "the
action to impugn the legitimacy."
This action can be brought only by the husband or his heirs and within the
periods fixed in the present articles.
Legitimacy and filiation can be questioned only in a direct action
seasonably filed by the proper party, and not through collateral attack.
****Nota bene: The same rule is applied to adoption such that it cannot also be
made subject to a collateral attack.