The Supreme Court’s decision in Maria T. Calma v. Marilu C. Turla underscores that determining maternity does not automatically exclude paternity. The Court emphasized that a DNA test disproving a special administratrix’s relationship to the deceased’s wife does not necessarily negate her claim as the daughter of the deceased himself. This ruling clarifies the importance of directing DNA testing toward the specific relationship in question when determining heirship and the administration of estates.

Whose Daughter Is She? DNA, Birth Certificates, and the Battle for Mariano Turla’s Estate

The heart of this case lies in a dispute over the estate of the late Mariano C. Turla. Marilu C. Turla petitioned for letters of administration, claiming to be Mariano’s sole legal heir. Her claim was based on her birth certificate, which identified Mariano as her father and Rufina de Castro as her mother. However, Maria T. Calma, claiming to be Mariano’s half-sister, opposed the petition, asserting that Marilu was not Mariano’s daughter and that the birth certificate was falsified. This opposition led to a series of legal maneuvers, including a contested DNA test and the removal of Marilu as the special administratrix of the estate. The central legal question revolves around the validity and scope of DNA evidence in determining filiation and the subsequent right to administer an estate.

The Regional Trial Court (RTC) initially granted Maria’s motion for DNA testing to determine Marilu’s paternity. However, the DNA test was conducted using samples from Rufina’s alleged siblings, and the results indicated that Marilu was not maternally related to Rufina. Based on this, the RTC removed Marilu as the special administratrix. The Court of Appeals (CA) reversed this decision, finding that the RTC had acted with grave abuse of discretion. The CA reasoned that disproving Marilu’s relationship to Rufina did not automatically disprove her relationship to Mariano, the deceased. The Supreme Court (SC) affirmed the CA’s decision, emphasizing that the DNA test did not address the core issue of Marilu’s paternity, which was the essence of the case.

The Supreme Court underscored that the selection and removal of special administrators are governed by different rules than those for regular administrators, stating, “Courts may appoint or remove *special* administrators based on grounds other than those enumerated in the Rules, at their discretion.” It emphasized, however, that this discretion must be exercised judiciously, “based on reason, equity, justice and legal principles.” The Court agreed with the CA that the RTC had overstepped its bounds by relying on a DNA test that did not directly address the crucial issue of Marilu’s filiation with Mariano Turla. The decision highlighted the importance of ensuring that evidence presented and relied upon is both material and relevant to the specific legal question at hand.

Furthermore, the Court scrutinized the procedural aspects of the DNA evidence, referencing Section 5 of A.M. No. 06-11-5-SC, the Rule on DNA Evidence. This rule states that the grant of a DNA testing application does not automatically ensure the admission of any resulting DNA evidence. The Court noted that in this case, the DNA results were not properly offered as evidence, further weakening the basis for the RTC’s decision to remove Marilu as special administratrix. The ruling serves as a reminder of the importance of adhering to the rules of evidence when presenting and evaluating scientific evidence in legal proceedings. To emphasize this point, the Court cited the CA’s disquisition:

The estate to be administered is that of decedent Mariano Turla, hence, it is grave abuse of discretion on the part of the Respondent Judge to remove petitioner on the ground that she is not related to Rufina Turla. True, that she claims to be the daughter of the Spouses Mariano Turla and Rufina Turla. However, a finding that she is not the daughter of Rufina Turla does not automatically mean that she is not the daughter of Mariano Turla as well, especially since in the two versions of her birth certificate, it was Mariano Turla who reported her birth and who signed the same as the father of the child.

The Court’s analysis also addressed the petitioner’s argument that Mariano’s affidavit of adjudication, executed in 1994 for the extrajudicial settlement of his late wife Rufina’s estate, disproved Marilu’s claim. In that affidavit, Mariano had stated that Rufina did not leave any descendants. The Court dismissed this argument, asserting that the affidavit concerning Rufina’s estate did not conclusively determine Marilu’s parentage in the context of Mariano’s estate. This highlights the principle that statements made in one legal context do not automatically bind or determine outcomes in different legal contexts, especially when dealing with matters of filiation and inheritance.

Finally, the Court addressed the petitioner’s claim that Marilu had violated her duties as special administratrix. The petitioner argued that Marilu had failed to submit a proper inventory and accounting of the estate’s assets. The Court noted that Marilu had submitted an initial accounting and that the directive to submit a full inventory and accounting came as part of the RTC’s order removing her as special administratrix. Since that order was challenged and ultimately reversed, the Court found no basis to fault Marilu for non-compliance. This part of the ruling underscores the importance of due process and the principle that a party should not be penalized for failing to comply with an order that is itself subject to legal challenge.

FAQs

What was the central issue in this case?	The central issue was whether the special administratrix of an estate could be removed based on a DNA test proving she was not related to the deceased’s wife, even though her relationship to the deceased himself was not disproven.
Why did the Supreme Court rule in favor of Marilu Turla?	The Supreme Court ruled in favor of Marilu Turla because the DNA test only disproved her relationship with Rufina, the deceased’s wife, and did not address whether Mariano Turla was her father. The court found that the RTC acted with grave abuse of discretion by relying on this irrelevant evidence.
What is a special administrator?	A special administrator is appointed by the court to manage an estate temporarily, typically when there is a dispute over who should be the permanent administrator or when there are delays in the estate settlement process. Their role is to preserve the estate’s assets until a regular administrator is appointed.
How does this case affect the use of DNA evidence in estate cases?	This case emphasizes the importance of ensuring that DNA evidence is directly relevant to the specific relationship being questioned. A DNA test intended to prove paternity must actually test the relationship between the child and the alleged father, not just other family members.
What is the significance of the Rule on DNA Evidence in this case?	The Rule on DNA Evidence (A.M. No. 06-11-5-SC) states that obtaining DNA results does not automatically mean they are admissible in court. The results must be properly offered as evidence and evaluated according to the rules of evidence, which was not done in this case.
What was the basis for Maria Calma’s opposition to Marilu Turla’s petition?	Maria Calma opposed Marilu Turla’s petition on the grounds that Marilu was not Mariano Turla’s daughter and that her birth certificate was fraudulent. Calma claimed to be Mariano’s half-sister and therefore a rightful heir to the estate.
Can an affidavit made in one estate case affect another estate case?	The Supreme Court held that an affidavit made in one estate case (the settlement of Rufina’s estate) does not automatically determine outcomes in another estate case (the settlement of Mariano’s estate). Each case must be evaluated on its own merits and evidence.
What are the duties of a special administratrix?	A special administratrix has duties such as submitting an inventory of the estate’s assets and providing an accounting of the funds that come into her possession. However, failure to comply with these duties cannot be used as a basis for removal if the order to comply is part of an order that is being legally challenged.

The Supreme Court’s decision in Calma v. Turla provides valuable insights into the nuances of estate administration and the proper use of DNA evidence in determining filiation. By clarifying the scope and relevance of DNA testing and emphasizing the importance of procedural due process, the Court has reinforced the need for careful and reasoned decision-making in estate proceedings.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MARIA T. CALMA v. MARILU C. TURLA, G.R. No. 221684, July 30, 2018