GR 89224 25; (January, 1992) (Digest)
G.R. Nos. 89224-25. January 23, 1992.
Mauricio Sayson, et al., petitioners, vs. The Honorable Court of Appeals, Delia Sayson, et al., respondents.
FACTS
The petitioners, siblings of the deceased Teodoro Sayson and his mother-in-law, filed for partition of the intestate estate of Teodoro and his wife Isabel. The action was resisted by the private respondents—Delia, Edmundo, and Doribel, all surnamed Sayson—who claimed to be the exclusive heirs as Teodoro and Isabel’s children. In a separate but related case, the private respondents sought partition of the estate of Teodoro’s parents, Eleno and Rafaela Sayson, asserting a right of representation to Teodoro’s share. The trial courts ruled in favor of the private respondents, recognizing a 1967 decree of adoption for Delia and Edmundo and Doribel’s status as a legitimate child based on her birth certificate.
The Court of Appeals consolidated the appeals and affirmed the trial courts regarding the exclusivity of the private respondents’ inheritance from Teodoro and Isabel. However, it modified the decision concerning the grandparents’ estate, disqualifying the adopted children, Delia and Edmundo, from inheriting from Eleno and Rafaela by right of representation, while affirming that right for the legitimate daughter, Doribel. The petitioners sought review, challenging the validity of the adoption and Doribel’s legitimacy.
ISSUE
The primary issue is whether the private respondents are the exclusive heirs of Teodoro and Isabel Sayson and whether they can inherit from the estate of Teodoro’s parents, Eleno and Rafaela Sayson.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The collateral attack on the 1967 decree of adoption is impermissible. A final decree of adoption can only be assailed in a direct proceeding; it cannot be overturned in a partition case. The petitioners’ inconsistent stance—arguing the adoption is invalid because a legitimate child (Doribel) existed, while simultaneously denying Doribel is legitimate—further undermines their position. The presumption of regularity favors the adoption decree and Doribel’s birth certificate.
On the substantive rights of inheritance, the Court held that Delia, Edmundo, and Doribel, as the adopted and legitimate children of Teodoro, are his exclusive heirs, excluding the petitioners from his estate. Concerning the grandparents’ estate, only Doribel, as a legitimate granddaughter, inherits by right of representation under Article 981 of the Civil Code. Adopted children, while enjoying the rights of legitimate children relative to their adoptive parents, do not acquire the right of representation to the estate of the adoptive parents’ own ascendants. The relationship created by adoption is generally confined to the adopter and the adopted. Thus, Delia and Edmundo cannot represent Teodoro in the inheritance from Eleno and Rafaela.