Congenital epulis is a very rare lesion found only in newborn infants. This tumor is multiple in about 10% of reported cases, rarely with the simultaneous involvement of the maxilla and mandibula, as in this article. In the presented case, light microscopy demonstrated large eosinophilic granular cells arranged in solid nests that are separated by thin fibrovascular areas. The tumors in the maxilla and mandibula were investigated with a panel of polyclonal and monoclonal antibodies, and using immunoperoxidase methods on formalin-fixed, paraffin-embedded sections. Immunohistochemical studies revealed strong and diffuse cytoplasmic staining for neuron specific enolase and vimentin. However, all other reactions were negative. These results suggest that the congenital epulis may be derived from uncommitted nerve-related mesenchymal cells.