
A petition filed by the sister and nephews of the late film director Edwin “Wenn” Deramas seeking a court-ordered DNA test to resolve a dispute over his properties and bank deposits was denied by the Court of Appeals.
In an 11-page decision penned by Associate Justice Germano Francisco Legaspi dated 8 September 2025, the CA’s Fifteenth Division affirmed the Quezon City RTC ruling denying the petitioners’ request to conduct DNA testing on Deramas’ children, Gabriel Michael and Raphaella.
Deramas’ sister and three nephews argued that the DNA test was necessary to settle a case they filed against Gabriel and Raphaella for ownership of two parcels of land—“Bahay Toro” and “Bahay Balara,” both in Quezon City—and bank deposits. They claimed the children are not Deramas’ biological offspring, citing that the director was openly gay and that their mother, Ariane Manalo, is openly lesbian.
The petitioners said that Deramas had informally adopted Gabriel in 2000 and Raphaella in 2010, treating them as his own children and convincing Manalo to do the same. After Deramas’ passing, the petitioners executed an extrajudicial settlement adjudicating his estate entirely to themselves, and asked the private respondents to vacate the properties.
Gabriel and Raphaella asserted that they should share in Deramas’ estate as compulsory heirs. In 2023, petitioners claimed they were surprised to learn that the children had transferred the disputed properties to their names, prompting their filing of a reconveyance case and request for a DNA test.
The trial court ruled that DNA testing was unnecessary, as the children’s birth certificates sufficiently proved their parentage.
The CA upheld the ruling, noting that DNA testing remains discretionary, especially when preponderance of evidence already establishes paternity. The court rejected arguments based on the sexual orientation of Deramas and Manalo.
“Certainly, the denial of a motion for DNA testing is warranted when the request is premised solely on such tenuous or insubstantial grounds,” the CA ruled.
The Court added: “This holds true all the more in this case where petitioners’ allegations are met with Raphaella and Gabriel’s certificates of live birth, which as public documents, carry considerable evidentiary weight, such that a high degree of proof is needed to overthrow the presumption of the truth contained in such public documents.”