Reyes vs. Sotero, GR No. 167405, February 16, 2006 - Digested: (Special Proceedings - Adoption)
Reyes vs. Sotero, GR No. 167405, February 16, 2006 - Digested: (Special Proceedings - Adoption)
Reyes vs. Sotero, GR No. 167405, February 16, 2006 - Digested: (Special Proceedings - Adoption)
167405,February
16,2006_digested
PostedbyPiusMoradosonMarch27,2012
(Special Proceedings Adoption)
Facts: Respondent Chichioco filed a petition for the issuance of letters of administration and settlement of
estate of the late Elena Lising claiming that she was the niece and heir of Lising who died intestate.
Respondent claims that real and personal properties were allegedly in the possession of petitioner Ana
Joyce S. Reyes, a grandniece of the deceased.
Petitioner Reyes filed an Opposition to the petition, claiming that she was an adopted child of Lising and the
latters husband and asserting that the petition be dismissed since she was the only heir of Lising who
passed away without leaving any debts.
Subsequently, petitioner filed a Supplement to the Opposition attaching thereto the certification of her
adoption from the local civil registrars office that the adoption decree was registered therein and also a copy
of a Judicial Form and a certification issued by the clerk of court that the decree was on file in the General
Docket of the RTC-Tarlac.
Respondents filed a Comment to the opposition stating that reasonable doubts have been cast on
Petitioners claim that she was legally adopted due allegedly to certain badges of fraud.
The appellate court refused to dismiss the proceeding because it was incumbent upon the petitioner to prove
before the trial court that she was indeed adopted by the Delos Santos spouse since, imputations of
irregularities permeating the adoption decree render its authenticity under a cloud of doubt.
Issue: WON petitioner had to prove the validity of her adoption due to imputations of irregularities.
Held: No. Petitioner need not prove her legal adoption by any evidence other than those which she had
already presented before the trial court.
An adoption decree is a public document required by law to be entered into public records, the official
repository of which, as well as all other judicial pronouncements affecting the status of individuals, is the
local civil registrars 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 petitioners 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 petitioners 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.