In re Raphael P

In In re Raphael P. (2002) 97 Cal.App.4th 716, the Court of Appeal reversed an order denying a man presumed father status and remanded for reconsideration of the issue, holding that "once appellant provided prima facie proof that he signed a voluntary declaration of paternity, as he did by showing his name was on the birth certificate, he was entitled to rely upon the presumption of Evidence Code section 664 to establish that the document was properly filed with the Department of Child Support Services, and it was the child welfare agency's burden to disprove this fact." (Raphael P., supra, 97 Cal.App.4th at p. 738.)