Professional Documents
Culture Documents
Morales)
Malang vs Moson (2000)
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Lilian Dy
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June 2005 Artadi filed again with 2 district Shari'a court Marawi City
dismissed again for res judicata and forum-shopping
th
Oct 2005 Artadi filed with 4 Disc Shari's court new evidence,
identity of causes not present
nd
Try the case again in 2 Shari'a Court former case refers to
neglect pre-1994, new case neglect since 1996-2005.
Lilian Dy
Tenebro vs CA (2004)
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Breach of Promise
1987 GSB (Iranian) promised to marry Marilou Gonzales (22yrs)
Gonzales a virgin before living in (forced) with GSB, GSB changed,
maltreated her and withdrew his offer of marriage already married to
someone from Bacolod (not true single pa talaga)
RTC : Gonzales won 20T moral damages, 3T attorney's fees, 2T
expenses
GSB deceitful cause of deflowering
Gonzales and parents already announced her imminent marriage
and started preparations
GSB did not propose marriage (daw)
Art 21 moral wrongs
Supreme Court upholds decision
Silverio vs RP (2007)
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CA overturned decision
SC Change of name a privilege and not a right (RA 9048 Change
of first name, jurisdiction under civil registrar, administrative officers)
SC petitioner failed to show or allege that he may suffer from using
his real name
Sex cannot be a clerical or typographical error
Status of person cannot in law includes all his personal qualities and
relations, more or less permanent in nature, not ordinarily
terminable at his own will
No special law governing sex re-assignment
SC Re: RTC's reasons of equity and justice assume no harm to
anyone, but accdg to SC, decision affects many laws, especially
Marriage and Family relations, penal, labor laws that affect women,
etc.
Court cannot make or enact laws, only interpret them.
Lilian Dy
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RP vs Cagandahan
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Characters:
o Godofredo Buccat: husband, plaintiff-appelant
o Luida Mangonon de Buccat: wife; respondent-appealee
ISSUE:
Lilian Dy
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Whether the marriage is annullable even if consent was given through fraud
Domingo vs CA (1993)
HELD/DECISION:
Karl Heinz Weigel asks for declaration of Nullity of marriage with Lilia
Weigel (1978) due to Lilia's previous marriage to Eduardo Maxion in
1972
Lilia says marriage to Eduardo was void due to lack of consent, also
first husband already married to someone else in 1972 before he
married her.
Force or duress of first marriage only makes it voidable and not void,
needs judicial declaration of such fact. Marriage to Karl Weigal VOID.
Dorothy Terre charged Jordan Terre with gross immoral conduct for
contracting a second marriage while still married to her.
So v Valera (2009)
Lilian Dy
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Ty v CA (2000)
st
Lilian Dy
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Engrace Ninal (as guardian of Babyline, Ingrid, Archie & Pepito Ninal Jr)
v Norma Bayadog (Mar 14 2000)
May the heirs of a deceased person file a petition for the declaration
of nullity of his marriage after his death?
26 Sep 1974 Pepito Ninal married Teodulfa Bellones
24 Aprl 1985 Pepito shot to death Teodulfa
11 Dec 1986 Pepito and Norma Badayog got married w/o marriage
license, executed affidavit that they had lived together for 5 years as
husband and wife
19 Feb 1997 Pepito died in a car accident
Heirs then filed petition to declare second marriage void for lack of
marriage license. Norma filed to dismiss bec heirs not among
persons who can file an action for annulment of marriage
RTC dismissed case. Should have filed before Pepito's death.
SC marriage of Pepito and Norma void ab initio due to Pepito's
subsisting marriage during claimed period of cohabitation
SC any proper interested party may attack a void marriage.
SC Second marriage was void ab initio
Barcelona vs CA (2003)
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x x x.
(d) What to allege. A petition under Article 36 of the Family Code
shall specifically allege the complete facts showing that either or both
parties were psychologically incapacitated from complying with the
Lilian Dy
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Zamora vs CA (2007)
Antonio vs Reyes (2006)
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Amor-Catalan vs CA (2003)
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Lilian Dy
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4 July 1994 Lester (21) and Chona (19) when they married in City
Hall of Manila
After wedding, continued to live with parents and never lived together
though maintained relationship
1 year after, couple bickered constantly, Lester dated other women,
received prank calls
Lester filed petition for declaration of nullity of marriage due to his
psychological incapacity to fufil essential marital obligations. He
thought wedding was a joke and marriage certificate a fake, never
lived together or consummated their marriage
RTC granted petition
CA reversed RTCs ruling due to failure of Lester to establish his
psychological incapacity
Dr. Dayan, Lester suffered from mixed personality disorder from selfdefeating personality to dependent personality disorder due to
dysfunctional family background.
SC upholds CA's ruling. No psychological incapacity.
Petition for review of RTC and CA's ruling in 2005 declaring marriage
null on grounds of psychological incapacity of Nilda
29 Dec 1988 Nilda and Reynaldo married despite Reynaldo
knowing the fact that Nilda had penpals (asking for money) and an
illegitimate son by unknown man.
18 Jun 1992 Reynaldo left Nilda for good because of her behavior
(flirty, introduced herself as single, refused to have a child with him
as it would ruin her figure, etc)
30 Aug 1999 Reynaldo filed a petition for declaration of absolute
nullity of marriage and damages. Citing Art 36 (promiscuity, etc)
Accdg to Clinical Psychologist and Social Worker Leticia Vatanagul,
Nilda a nymphomaniac, borderline personality, social deviant,
alcoholic, anti-social personality disorder, among others, Incurable.
Nilda Reynaldo is the one at fault womanizer, doesn't share his
earnings. He knew about her child. She uses the name Navales, only
teaches women.
SC Nilda and Reynaldo's marriage not void. Nilda not
psychologically incapacitated. No root cause of psychological
incapacity, no corroboration of facts asserted by Reynaldo.
Lilian Dy
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Only a spouse can initiate an action to sever the marital bond for
marriages solemnized during the effectivity of the FC, except in
cases commenced prior to March 15, 2003.
Felix Carlos and Felipa Elemia died intestate, left 6 parcels of land to
Teofilo Carlos and Juan de Dios Carlos
SC married valid
Lilian Dy
Arts 1338-1344 CC
Art. 1338. There is fraud when, through insidious words or machinations of
one of the contracting parties, the other is induced to enter into a contract
which, without them, he would not have agreed to. (1269)
Art. 1339. Failure to disclose facts, when there is a duty to reveal them, as
when the parties are bound by confidential relations, constitutes fraud. (n)
Art. 1340. The usual exaggerations in trade, when the other party had an
opportunity to know the facts, are not in themselves fraudulent. (n)
Art. 1341. A mere expression of an opinion does not signify fraud, unless
made by an expert and the other party has relied on the former's special
knowledge. (n)
Art. 1342. Misrepresentation by a third person does not vitiate consent,
unless such misrepresentation has created substantial mistake and the same
is mutual. (n)
Art. 1343. Misrepresentation made in good faith is not fraudulent but may
constitute error. (n)
Art. 1344. In order that fraud may make a contract voidable, it should be
serious and should not have been employed by both contracting parties.
Incidental fraud only obliges the person employing it to pay damages. (1270)
Buccat vs Buccat
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Lilian Dy
Lilian Dy
DATE: May 31, 1940
NATURE: annulment of marriage on the ground of impotency
FACTS:
June 3, 1936: Felix Sarao and Pilar Guevarra were married
Felix wanted to have carnal knowledge of Pilar but she was reluctant
and said that they should wait till the evening
Felix found the orifice of Pilars vagina sufficiently large for his organ
but she complained of pains in her private part and he noticed oozing
therefrom some purulent matter offensive to the smell
Coitus was not a success
Every attempt on Felixs part to have a carnal act with hid wife
proved a failure because she complained of pains in her genitalia
Pilar had a medical check up and found out that her uterus and
ovaries were affected with tumor; the organs were surgically
removed with the consent of Felix
The surgery rendered Pilar incapable of procreation but did not
incapacitate her of copulation
Felix after the operation lost all desire to have access with his wife
and has not tried to do it since
RTC: dismissed complaint
ISSUES:
Whether the marriage may be annulled on the ground of impotency
HELD/DECISION:
No. Dismissed complaint
RATIO:
Sarao vs Guevarra
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in Tolentino Book
PONENTE: Reyes, A.
Sec. 30 Act No. 3613: Marriage may be annulled if either party was,
at the time of marriage, physically incapable of entering into the
married state, and such incapacity continues, and appears to be
incurable
Lilian Dy
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People vs Santiago
Rene Puse vs Ligaya Puse (15 March 2010)
Lilian Dy
license with the proper local civil registrar which shall specify the
following: (5) if previously married, how, when and where the
previous marriage was dissolved or annulled;
ART. 13 FC: in case either of the contracting parties has been
previously married, the applicant shall be required to furnish, instead
of the birth or baptismal certificate required in the last preceding
article, the death certificate of the deceased spouse or the judicial
decree of absolute divorce, or the judicial decree of annulment or
declaration of nullity of his or her previous marriage.
ART. 52 FC: the judgment of annulment or of absolute nullity of the
marriage, the partition and distribution of the properties of the
spouses, and the delivery of the childrens presumptive legitimes
shall be recorded in the appropriate civil registry and registries of
property; otherwise the same shall not affect their persons
Before a foreign judgment is given presumptive evidentiary value,
the document must first be presented and admitted in evidence. A
divorce obtained abroad is proven by the divorce decree itself.
Indeed the best evidence of a judgment is the judgment itself. The
decree purports to be a written act or record of an act of an official
body or tribunal of a foreign country.
SEC. 24 and 25 of Rule 132: a document may be proven as a public
or official record of a foreign country by either (1) an official
publication, or (2) a copy thereof attested by the officer having legal
custody of the document. If the record is not kept in the Philippines,
such copy must be (a) accompanied by a certificate issued by the
proper diplomatic or consular officer in the Philippine foreign service
stationed in the foreign country in which the record is kept, and (b)
authenticated by the seal of his office.
2 types of divorce: absolute (terminates marriage) and limited
divorce (suspends it and leaves the bond in full force)
Recio presented a decree nisi or an interlocutory decree: a
conditional or provisional judgment of divorce.
A party to a marriage who married again before this decree becomes
absolute (unless the other party has died) commits the offence of bigamy.divorce obtained has been restricted and does not establish legal capacity to
m
Homeowners Savings & Loan Bank vs Miguela Dailo (2005)
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Lilian Dy
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Lilian Dy
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Lilian Dy
filed a complaint for quieting of title and damages.
Issues:
1. WON the construction of a conjugal house on the exclusive
property of the husband ipso facto gave the land the character of
conjugal property.
t. 158 of the CC provides: Improvements, whether for utility
or adornment, made on the separate property of the spouses
through advancements from the partnership or through the industry
of either the husband or the wife, belong to the conjugal partnership.
Buildings constructed, at the expense of the partnership, during the
marriage on land belonging to one of the spouses, also pertain to the
partnership, but the value of the land shall be reimbursed to the
spouse who owns the same. (1404a)
but the
conjugal partnership is indebted to the husband for the value of the
land.
conversion from paraphernal to conjugal
assets should deemed to retroact to the time the conjugal assets
were constructed thereon. Cannot be considered to become conjugal
property only at the time their values were paid to the estate because
by that time the conjugal partnership no longer existed and it could
not acquire the ownership of the properties
Mercedes had
not given her consent to the sale.
2. WON the sale of the lot together with the house and
improvements
thereon was valid under the circumstances surrounding the
transaction
Contract of sale is null and void for being contrary to morals
and public policy. Sale was made by the husband in favour of a
concubine after he had abandoned his family and left the conjugal
home where his wife and children lived and from whence they
derived their support. Sale was subversive of the stability of the
family, a basic social institution which public policy cherishes and
protects.
Lilian Dy
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contrary to
law, morals, good customs, public order, or public policy are void and
inexistent
from the very beginning.
cause,
produce no effect whatsoever. The cause is unlawful if it is contrary
to law,
morals, good customs, public order or public policy.
each other.
The prohibition also applies to a couple living as husband and wife
without the benefit of marriage, otherwise the condiion of those who
incurred guilt would
Metrobank vs Pascual (2008)
19 Jan 1985 Nicholson Pascual and FLorencia Nevalga married
During marriage bought 250sqm lot with 3 door apartment in Makati,
title registered as Florencia, married to Nelson Pascual aka
Nicholson Pascual
1994 Marriage declared null and void on ground of psychological
incapacity
Court ordered liquidation of CPG. However, they went their separate
ways w/o liquidating their conjugal partnership
30 Apr 1997. Florencia obtained a loan of 58M with spouses Oliveros
from Metrobank
Florencia submitted marriage-nullifying decision, waiver of Nicholson
(1995) of conjugal properties of ex-spouses, but this did not included
lot in question
Metrobank foreclosed on mortgages because of failure of Florencia
and Oliveros to repay loan.
Nicholson filed complaint 2000 because subject property mortgaged
w/o his consent. Nicholson also claimed waiver was a forgery.
Executed 3 mos before declaration of nullity.
RTC found for Nicholson property conjugal (Art 116). Mortgage
null and void.
CA affirmed RTCs ruling
Dimayuga-Laurena vs CA (2008)
Darlene and Jesse married in 1983
Petition for declaration of nullity of marriage denied (filed in 1993)
What constitutes the conjugal property?
SC - Duplex House in Makati City only Deed of Absolute Sale from
Felix Husband received a series of promotions so that they could
purchase the house in Makati, proof of conjugal property and not
property of parents
Other properties not part of CPG bec it was shown that they were
parents properties despite SPAs to husband and properties acquired
through income from parents businesses.
Villanueva vs IAC (1990)
Lot of Modesto mortgaged to Jesus Bernas (18K)by his 2 illegitimate
children, Dorothea Aranas Ado and Teodoro Aranas (Lot 13-C) 30
Oct 1975. Witness Raymundo Aranas
Dorothea and Teodoro failed to pay the loan. Bernas had the old title
cancelled and a new one issued in his name TCT T-15121 (1978)
24 Nov 1978 Consolacion Villanueva and Raymundo Aranas filed
a complaint against Jesus and Remedios Bermas. Discovery of 2
wills. Victoria (Modestos wife) willed her share of the CPG to
Consolacion Villanueva and Raymundo, Dorothea and Teodoro,
while Modesto willed his share to Dorothea and Teodoro
RTC found for the Bermas and found mortgage and transfer valid.
Lot 13-C not part of conjugal property of Victoria and Modesto as
Modesto inherited this from his parents exclusive property of
Modesto.
Victoria died before Modesto and so could not have inherited any
part of Lot 13-C
However, there are improvements on the property. Improvements
not conjugal in character as no proof was presented that the source
of funds for the improvements were conjugal.
Claims of Consolacion and Raymundo denied.
Lilian Dy
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1976, heirs of Maximo file a case against the Felipes regarding the
properties. They claimed it was mortgaged to the Felipes but that the
Felipes refused to have the properties redeemed.
RTC found for the Felipes. CA found for Gimena and heirs. Sale was
invalid as it was done without Maximos consent
Gimenas sale : voidable contract. Gimena had no capacity to give
consent to contract of sale. Only husband could have asked for
annulment of the contract of sale
When Maximo died, children inherited 2/3 of his share and could
question the sale
SC return property to children. Sale not valid. Petitioners in bad
faith.
Severino Sr had the right and authority to sell the Loring property
the husband is the administrator of the conjugal partnership Art 165
CC)
Though Teofista was the administratrix of the property, this was only
after the Rizal Court had already given Severino Sr. the authority to
sell the property. No public instrument proving Teofista administratrix
of conjugal properties before this.
Contract of Lease b/w Pentel and Teofista, void
Lilian Dy
Issue. Is the husbands consent required as the parent of a child born of
consensual AID?
In re Adoption of Anonymous
Citation. 345 N.Y.S.2d 430 (Surr. Ct. 1973)
In response to claims that AID constitutes adultery of the mother, the court
found that in the absence of legislation prohibiting artificial insemination, the
child was lawfully begotten and not the product of an illicit or adulterous
relationship.
A New York case finding that AID children are illegitimate is the only such
published decision and is unpersuasive. The historical concept and statutory
definition of a child born out of wedlock were enacted long before the advent
of artificial insemination. AN AID is not begotten by a father who is not the
husband. Since there is consent by the husband, there is no marital infidelity.
The problem is one of policy. New York has a strong policy in favor of
legitimacy, so it is absurd to hold illegitimate a child born during a valid
marriage, of parents desiring but unable to conceive a child, and both
consenting and agreeing to the impregnation of the mother by a medically
selected anonymous donor. This policy is for the protection of the child, not
the parents.
Cecilio Mendoza vs CA, Luisa dela Rosa Mendoza (1967)
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Lilian Dy
Art 155: exceptions to Art 153 (1) for non payment of taxes (2) debts
incurred prior to constitution of family home (3) mortgage on family
home (4) debts due to laborers, architects, builders, materialmen and
other who have rendered service or furnished materials for the
construction of the bldg.
SC - Became constituted as family home in 1988 and not 1972
because Family Code only effective since August 3, 1988. No
retroactive effect.
SC family home exempt? No, because the debt or liability which
was the basis of the judgement incurred in 1987, (before effectivity of
Family Code and constitution of family home) Also does not fall
under exemptions under Art 155.
SC petition dismissed.
Lilian Dy
Union Bank vd CA, Apolonia de Jesus Grogoria etc Gonzalo Vincoy m
to Triniradad Gregorio VIncoy (2001)
2 Mar 1990 Spouse Gonzalo and Trinidad Vincoy mortgaged their
residence in favor of petitioner (UB) to secure payment for a loan to
Delco Industris in the amount of 2M. For failure to pay loan, Union
Bank foreclosed mortgage and scheduled foreclosure sale on 10 Apr
1991. Highest Bid was 3.29M. Certificate of Sale issued and noted
on TCT on 8 May 1991
Prior to redemption period (8 May 1992), respondents filed complaint
for annulment of mortgage.
Property constituted as family home in 1989. Beneficiaries are
sisters of Trinidad who did not consent to mortgage. (Art 158)
Union Bank property cannot be constituted as family home bec
value exceed max value of 300T (Art. 157)
RTC mortgage valid, not family home pay Union Bank 4.816M++
CA affirmed RTC, not family home. Redemption amount 3.29M + 1%
monthly interest April 19 1991 date of redemption.
SC - respondents at no time ask to be allowed to redeem property
during RTC, so cannot raise issue in CA. Moreover, period of
redemption not interrupted by filing a case assailing validity of
mortgage. Affirmed RTC and CAs ruling except that Respondents
have lost their right of redemption.
Vilma & Anthony Arriola vs John Arriola (2008)
John Nabor filed for judicial partition of properties of Fidel Arriola
(exclusive property)
John son of Fidel with first wife Victoria
Anthony son of Fidel with second wife Vilma
2004 RTC property to be divided equally (1/3 each) to heirs John,
Anthony and Vilma.
Parties failed to agree on how to partition land. Finally agreed on
Public Auction, but this was cancelled bec Anthony and Vilma
refused to include auction of house.
RTC petitioners justified that house or improvement should not be
included in auction sale Presence of house not alleged in original
case.
CA granted Johns petition to auction land and house. House mere
accessory to land, part of estate.
Contempt (?)
Spouses Arthur & Doris Kelley Jr. vs Planters Products & Jorge
Ragutana (2008)
Planters Products filed a case for sum of money against Arthur due
to his failure to pay for agri chemicals bought from them.
RTC found for Planters. Sheriff Ragutana sold on execution real
property located in Naga City. Certificate of Sale issued to Planters
as highest bidder.
Arthur and Doris belatedly informed of sale. Filed case in RTC in
Makati that property was their family home and exempt, but denied
for failure to comply with 3 day notice reqm
Spouses Kelley then filed for nullity of levy and sale. Dismissed for
lack of jurisdiction and cause of action. Upheld by CA.
Family Home (1) must be the house where family actually resides. (2)
must be part of ACP, CPG or exclusive property of spouse with
latters consent, (3) Actual value at time of constitution shall not
exceed 300T in urban areas and 200T in rural areas.
SC Family Code no need to constitute the family home judicially
or extrajudicially. An exemption is effective from the time of the
constitution of the damily hoe as such and lasts as long as any of its
benificiaries reside there. Debts for which the family home is made
Lilian Dy
Lilian Dy
Lilian Dy
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Lilian Dy
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Lilian Dy
Lilian Dy
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Lilian Dy
Herbert Cang vs CA and Spouses Ronald & Maria Clara Clavano (1998)
Issue : Can minor children be legally adopted w/o the written consent
of a natural parent on the ground that the latter had abandoned them?
27 Jan 1973 Herbert Cang & Anne Marie Clavano married and had
3 children, Keith, Charmaine, and Joseph Anthony.
Because of Herberts affair with Wilma Soco, a family friend, Anne
Marie filed for legal sep, legal separation granted. Support for
children 1000, Anne Marie may be entitled to enter into contract or
agreement w/o written consent of husband, or any undertaking that
normally requires husbands consent.
Herbert left for US and got divorce decree from Anne Marie. Sole
Custody of children to Anne Marie reserving rights of visitation at
reasonable times and places.
Herbert married and divorced an American. Became naturalized
Amer. Citizen
Cang worked in the US, earning 18-20K a month, remitting portion
for support of children in childrens name in RP bank.
25 Sep 1987. Clavanos, brother and sister-in-law of Anne Marie filed
for adoption of 3 children.
14 yr old Keith gave consent. Anne Marie going to US to attend to a
family business. Cang not giving support and forfeited parental rights,
so better for children to be adopted by brother.
Upon learning of petition, Cang returned to RP and protested being
stripped of his parental authority even if his resources were meager
compared to Clavanos.
Lilian Dy
Habeas Corpus of minor Angelie Anne Cervantes, (spouses Nelson &
Zenaida) vs (Gina & Conrado Fajardo) 1989
29 April 1987- Affidavit of Consent issued by Gina & Conrado re
adoption of their 2-week old child by Ginas sister and brother in-law
(Nelson & Zenaida)
20 Aug 1987 RTC granted decree of adoption to the Cervantes
Mar or April 1987 adoptive parents received a letter asking them
for 150K to proceed with the adoption, (or else they will take back
their child). Cervantes refused
11 Sep 1987 Gina went to Cervantes house and conned the yaya
into giving her the child.
Gina told the court that she did not understand the implications of
giving up her child, affidavit of consent not explained to her. But
social worker said that Gina expressed her desire to have the child
adopted
SC best interests of the child most important (not necessarily all
children under 5 should be with their natural mother
SC Gina common-law wife of Conrado. Conrado legally married to
someone else. Not a good environment for the moral upbringing of
the child. Gina also has another child by a married man who left her.
Gina jobless
SC custody and care of Angelie to Cervantes. Judicial decree of
Adoption final, Parental authority transferred to Cervantes
Republic vs CA & Maximo Wong (1992)
CA granted pet of Maximo Wong to change his name to Maximo
Alcala Jr, w/c was his name prior to his adoption by Hoong Wong
and Concepcion Ty Wong.
9 Sep 1967, Maximo and Margaret, legitimate children of Maximo
Alcala Sr and Segundina Alcala. When they were 2-1/2 yrs and 9 yrs
old, siblings were adopted by the Wongs, insurance agent and HS
teacher, childless. Showered them with love and reared them as own
children.
Maximo when he was 22 pet to change his name as it embarrassed
and isolated him from his relatives and friends, as the name suggest
Chinese ancestry when he is a Muslim Filipino residing in Muslim
Community. Hampered by name in business and social life. With
Consent of adoptive mother.
Issue : Are reasons for change of name valid.
SC yes, reason for change of name valid, does not affect the legal
capacity, civil status or citizenship. Affirmed CAs ruling.
Lilian Dy
retroactive granting of parental authority. Still under Bundocs
supervision. Art 35 of PD 603. Bundocs liable.
Mauricio Sayson etal vs CA, Edmundo & Doribel Sayson (1992)
Issue Capacity of private respondents to inherit from alleged
parents and grandparents.
Eleno and Rafaela Sayson begot 5 children: Mauricio, Rosario,
Remedios, Basilisa and Teodoro
10 Nov 1952 Eleno died, 15 May 1976 Rafaela died.
Teodoro and his wife Isabel died leaving their properties in
possession of alleged children Delia, Edmundo and Doribel.
25 Aprl 1983 - Siblings of Teodoro filed for accounting and partitions
of Teodoro and Isabels estate. Resisted by respondents
11 July 1983 3 respondents filed for accounting and partition of
estate of Eleno and Rafaela. Accdg to case, Delia and Edmundo
adopted children of Teodoro while Doribel legit daughter, so they
were entitled to Teodoros share in his parents estate by right of
representation.
Both cases decided in favor of respondents
CA Delia and Edmundo legally adopted through judicial decree in 9
Mar 1967, Doribel leg daughter based on birth cert.
Mauricio Adoption after Doribel had been born in 1967, so it was
illegal. Inconsistent as petitioners also allege that Doribel is not legit
daughter.
SC Too late to question adoption
Collaterally challenging adoption not allowed.
Doribels legitimacy proved by birth cert. Presumption of Legitimacy.
Can only be impugned by direct Action.
SC Only Doribel entitled to estate of grandparents as Legitimate
Child. Adopted children no relation to grandparents.