FACTS: On September 15, 1998, respondent Corazon L. Chichioco filed a petition for the issuance of letters of administration and settlement of estate of the late Elena Lising before the RTC of Paniqui, Tarlac, where it was docketed as Spec. Proc. No. 204 and raffled to Branch 67. Chichioco claimed that she was the niece and heir of Lising who died intestate on July 31, 1998. According to Chichioco, the deceased left real properties located in the municipalities of Ramos and Paniqui, Tarlac, as well as assorted pieces of jewelry and money which were allegedly in the possession of petitioner Ana Joyce S. Reyes, a grandniece of the deceased. Chichioco prayed that she be appointed administrator of the estate, upon payment of a bond, pending settlement and distribution of Lising’s properties to the legal heirs. On November 6, 1998, petitioner Reyes filed an Opposition to the petition, claiming that she was an adopted child of Lising and the latter’s husband, Serafin Delos Santos, who died on November 30, 1970. She asserted that the petition should be dismissed and that the appointment of an administrator was unnecessary, since she was the only heir of Lising who passed away without leaving any debts. She further asserted that Chichioco is unfit to serve as administrator of Lising’s estate because of her “antagonistic interests” against the decedent. Chichioco and her alleged co-heirs have questioned the decedent’s title to a piece of real property which forms a large part of the estate. On November 11, 1998, petitioner filed a Supplement to the Opposition attaching thereto the Certification issued by the Municipal Civil Registrar of Paniqui, Tarlac stating that on page 76, Book No. 01 of the Register of Court Decrees, Reyes was adopted by Elena Lising and Serafin Delos Santos pursuant to a decision rendered in Spec. Proc. No. 1410 by Judge Julian Lustre of the Court of First Instance (CFI) of Tarlac and duly registered with the Office of the Civil Registrar on January 29, 1969. Petitioner also submitted a Certification issued by the Clerk of Court of the RTC-Tarlac City, stating that a judgment was rendered in Spec. Proc. No. 1410 on December 21, 1968 decreeing petitioner’s adoption by Elena Lising and Serafin Delos Santos. She also presented a copy of Judicial Form No. 43 indicating that the adoption decree was on file in the General Docket of the RTC-Tarlac City. Petitioner likewise submitted a Decree of Final Distribution issued by the Philippine Veterans Affairs Office (PVAO) showing that, upon the death of Serafin Delos Santos, death benefits were paid to his widow, Elena Lising, and his “daughter”, Ana Joyce Delos Santos, in accordance with pertinent provisions of law.Meanwhile, on June 30, 1999, Chichioco and her alleged co-heirs filed before the Court of Appeals a petition for annulment of the adoption decree docketed as SP No. 53457. They claimed that no proceedings for the adoption of petitioner took place in 1968 since the Provincial Prosecutor of Tarlac and the Office of the Solicitor General (OSG) had no records of the adoption case. Petitioner’s natural mother supposedly connived with the court personnel to make it appear that petitioner was adopted by the Delos Santos spouses and that the CFI’s order for initial hearing was published in a weekly newspaper which was not authorized to publish court orders in special proceedings. On November 16, 2000, respondents filed a Comment to the opposition stating that reasonable doubts have been cast on petitioner’s claim that she was legally adopted due allegedly to certain “badges of fraud.” Respondents also informed the RTC that they have filed a criminal complaint against petitioner before the Office of the Provincial Prosecutor, Tarlac City, for alleged falsification of the adoption.

ISSUE: Whether or not the imputations of irregularities permeating the adoption decree render its authenticity under a cloud of doubt.

HELD: On the first assigned error, we agree with petitioner that she need not prove her legal adoption by any evidence other than those which she had already presented before the trial court. To recall, petitioner submitted a certification from the local civil registrar’s office that the adoption decree was registered therein and also a copy of Judicial Form No. 43 and a certification issued by the clerk of court that the decree was on file in the General Docket of the RTC-Tarlac City. Both certifications were issued under the seal of the issuing offices and were signed by the proper officers. These are thus presumed to have been regularly issued as part of the official duties that said public officers perform. It should be borne in mind that an adoption decree is a public document required by law to be entered into the public records, the official repository of which, as well as all other judicial pronouncements affecting the status of individuals, is the local civil registrar’s office as well as the court which rendered the judgment. Documents consisting of entries in public records made in the performance of a duty by a public officer are prima facie evidence of the facts therein stated. As such, the certifications issued by the local civil registrar and the clerk of court regarding details of petitioner’s adoption which are entered in the records kept under their official custody, are prima facie evidence of the facts contained therein. These certifications suffice as proof of the fact of petitioner’s adoption by the Delos Santos spouses until contradicted or overcome by sufficient evidence. Mere “imputations of irregularities” will not cast a “cloud of doubt” on the adoption decree since the certifications and its contents are presumed valid until proof to the contrary is offered.

In this regard, it must be pointed out that such contrary proof can be presented only in a separate action brought principally for the purpose of nullifying the adoption decree. The latter cannot be assailed collaterally in a proceeding for the settlement of a decedent’s estate, as categorically held in Santos v. Aranzanso. Accordingly, respondents cannot assail in these proceedings the validity of the adoption decree in order to defeat petitioner’s claim that she is the sole heir of the decedent. Absent a categorical pronouncement in an appropriate proceeding that the decree of adoption is void, the certifications regarding the matter, as well as the facts stated therein, should be deemed legitimate, genuine and real. Petitioner’s status as an adopted child of the decedent remains unrebutted and no serious challenge has been brought against her standing as such. Therefore, for as long as petitioner’s adoption is considered valid, respondents cannot claim any interest in the decedent’s estate. For this reason, we agree with petitioner that Spec. Proc. No. 204 should be dismissed. Petitioner, whose adoption is presumed to be valid, would necessarily exclude respondents from inheriting from the decedent since they are mere collateral relatives of the latter.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s