CAMPUZANO

18 I. & N. Dec. 390
CourtBoard of Immigration Appeals
DecidedJuly 1, 1983
DocketID 2940
StatusPublished
Cited by2 cases

This text of 18 I. & N. Dec. 390 (CAMPUZANO) is published on Counsel Stack Legal Research, covering Board of Immigration Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CAMPUZANO, 18 I. & N. Dec. 390 (bia 1983).

Opinion

Interim Decision #2940

APPENDIX A LEGITIMATION Ecuador This report concerns the requirements for legitimation in Ecuador from 1936 to the present. During this time period, legitimation was apparently controlled by a number of provisions contained in the different constitutions that were successively .in force in the country and in the Civil Code. Since these provisions may not reveal a clear sequence, a brief legislative history follows. A. Civil Code Provisions in Force until the Enactment of the 1945 Constitution As of 1945, the Civil Code' established and defined two•basic catego- ries of children: legitimate and illegitimate. Legitimate children were those conceived during a fully valid or putative marriage of their parents, as well as those whose parents had married each other after their conception. Illegitimate children were those who had been voluntarily acknowledged as such by either parent or both parents, as well as those who had been declared to be so by judicial decision.' Regarding children born out of wedlock, the Code provided that they could be acknowledged by either parent or both parents. In such cases, these children were to enjoy the rights assigned to them by law in relation to the acknowledging parent or parents. 3 The acknowledgment of children could be made by means of a public instrument which could be: (a) notarial, (b) issued before a judge and three capable witnesses, (c) on a will, (d) a personal statement issued at the time of registration of the birth, or (e) a part of the marriage record of the parents. 4 A -child who had not been voluntarily acknowledged by the parents could peti- tion the courts to issue a declaration of filiation in regard with either parent or both parents.' A 1930 version of the Ecuadorean Civil Code as amended by Supreme Decree 94 of Nov. 23, 1935, was consulted for this part of the report: Codigo Civil (C. Civ. I] lTalleres Graficos Nacionales, Quito, 1930]. 2 C. Civ. I, arts. 30, 31 and 269. 3 C. Civ. I, arts. 267 and 271. 4 C. Civ. I, arts. 201 and 269. 5 C. Civ. I, arts. 277-289.

393 Interim Decision #2940

With regard to legitimation, the.Civil Code, as amended by Supreme Decree 94 of November 21, 1936, 6 provided that the marriage of the parents to each other produeed the effect of legitimating ipso itcre the children conceived or born prior to the celebration of that marriage."' Children born prior to the marriage who were not acknowledged by both parents did not benefit by the ipso jure legitimation by subsequent marriage of their parents; the acknowledgment by both parents as described above is necessary. This acknowledgment could take place at any time. In short, legitimation of children born out of wedlock required two basic elements: (1) acknowledgment of filiation by both parents and (2) subsequent marriage of the children's parents to each other'

B. Provisions of the 1945 Constitution On March 6, 1945, a new Constitution was enacted which provided that legitimate and illegitimate children had the same rights to support and inheritance. ° The new Constitution also provided that in registering births no statement could be required concerning the status of filiation." The Constitution did not farther elaborate on the effects of these new rules upon the existing provisions. of the Civil Code. The only other applicable provision was contained in article 163, which provided that any laws, decrees, regulations, ordinances, etc., which were in any way contradictory to it or which departed from its text had no validity.ii This Constitution was in force for only a few months, however, and therefore, according to Dr. Juan Larrea Holguin," its provisions did not affect other laws governing the subject or judicial decisions rendered on the matter after itvenactraent."

6 J. Torres, Compilation de Rqjormas at Codigo Civil, Leyes y Reglamentos Conexos (Talleres Graficos del Ministerio de Gobierno, Quito, 1942]. T Id. at 17, art. 11, amending C. Civ. I, art. 200.,

Civ. I, arts. 201 and 202. 9 Ccntstitucicm, art. 142 (3) (1945) [R. Borja y Borja, Las Constitaciones del Ecuador (Editions Culturallispanica, Madrid, 1951)] (hereinafter cited as Borja). 10 Id., art. 142 (4). This provision implied en important change in the existing system where the Registry of Births at the Civil. Registry was formed by three sections: (1) for legitimate children, (2) for illegitimate children, and (3) for children either abandoned or with unknown parents. u Constitution, art. 163 (1945) (Borja at 622). 38 Dr. Larrea Holguin is a professor of law at the Universidad Catolica del Ecuador, and author of numerous books and articles concerning civil laNi. He has also been active in the drafting of bills amending Civil Code provisions. 18 J. Larrea Holguin, Igualdodes de Los Conyuges e Igualdades de Los Hijos . '7-9 (Corporation de Estudios y Pubteaciones, Quito, 1967). ft,should also be noted that, in pieparing this report, several updated versions of the Civil Code were consulted and appear to contain no amendments based on the 1945 Constitution.

394 Interim Decision #2940

C. Provisions of the 1946 Constitution On December 31, 1946, the Constitution of 1945 was repealed and replaced by a new one which made a differentiation between legitimate and illegitimate children regarding inheritance rights." It also provided the following: Art. 165. The law shall regulate all matters relating to filiation and its rights and investigation of paternity. In registering births, no statement may be required concern- ing the status of filiation. No significant amendments were apparently introduced to the Civil Code concerning this subject; therefore, the legal status of filiation and legitimation remained the same as described in section A above until May 25, 1967, when a new Constitution entered into force."

D. Provisions of the 1967 Constitution The new. Constitution regulated this subject in the following terms: Art. 29. . . . Children, whether born in or out of wedlock, have the same rights with regard to name, upbringing, education and inheritance. The law shall regulate matters pertainingto filiation and shall facilitate investigation as to paternity. In registering births, no statement shall be required concerning the status of filiation.' This provision and others concerning various matters were contrary to the existing provisions of the Civil Code and related laws and regulations. The Constitution provided its own supremacy in the follow: ing terms: Art. 257. The Constitution is the supreme law of he State. All other laws must be in conformity with constitutional principles; therefore, any laws, decrees, regulations, ordinances, provisions, and public treaties that are in any way contradictory to it are null and void. Art. 260. This Constitution repeals all previous juridical precepts that are contrary to its provisions, whether issued by legitimate authorities or by de facto governments, so that any Jaws, decrees, regulations, decisions, orders, or resolutions issued before the Constitution takes effect shall be in force only insofar as they_are in conformity with it, and provided that they are not or have not been repealed or revoked, with the exception of rights validly acquired in accordance with such precepts.,

E. Current Civil Code Provisions Given the constitutional provisions in force, a new version of the Civil

a Constitution, art. 164 (1946) (Borja at 681). Is The new Constitution was enacted, published in the Registro Off iat and entered into force on the same date, May 25, 1967. 16 Constitution (1967) [Organization of American States, Washington, 1968) (English version).

395 Interim Decision #2940 Code was necessary in order to adapt its provisions to the new norms and to clarify the existing legal situation in several areas.

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Related

CROSS
26 I. & N. Dec. 485 (Board of Immigration Appeals, 2015)
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19 I. & N. Dec. 14 (Board of Immigration Appeals, 1983)

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Bluebook (online)
18 I. & N. Dec. 390, Counsel Stack Legal Research, https://law.counselstack.com/opinion/campuzano-bia-1983.