GR 125932; (April, 1999) (Digest)
G.R. No. 125932 April 21, 1999
Republic of the Philippines vs. Claude A. Miller and Jumrus S. Miller
FACTS
On July 29, 1988, spouses Claude A. Miller and Jumrus S. Miller, both American citizens, filed a petition for adoption of the minor Michael Magno Madayag with the Regional Trial Court of Angeles City. The natural parents, due to poverty, gave their irrevocable consent. The Department of Social Welfare and Development recommended approval, finding the Millers fit. The trial court granted the petition on May 12, 1989. The Republic, through the Solicitor General, appealed, arguing that the Family Code, which took effect on August 3, 1988, prohibits aliens from adopting Filipino children. The Court of Appeals certified the case to the Supreme Court as it involved pure questions of law.
ISSUE
Whether the trial court could grant the petition for adoption filed by alien spouses, considering that the Family Code, which disqualifies aliens from adopting, took effect after the petition was filed but before its adjudication.
RULING
The Supreme Court affirmed the trial court’s decision, ruling that the Millers’ right to adopt was governed by the Child and Youth Welfare Code (Presidential Decree No. 603), which was in force at the time of the filing of their petition on July 29, 1988. The Court held that the petitioners acquired a vested right under the law prevailing at the commencement of the action. A vested right is a present fixed interest that should be protected against arbitrary state action and includes an exemption from new obligations created after the right has vested. The jurisdiction of the court is determined by the statute in force at the time of the filing of the petition, and such jurisdiction, once attached, cannot be ousted by subsequent events or by a new law that would have prevented jurisdiction from attaching initially. Therefore, the subsequent enactment of the Family Code, which imposed a disqualification on aliens, could not impair the vested right of the respondents. The Court further emphasized that adoption statutes are humane and salutary, designed with the paramount consideration of the child’s welfare, and every reasonable intendment should be sustained to promote these objectives.