G.R. No. L-43955-56 July 30, 1979
RENATO LAZATIN alias RENATO STA. CLARA, petitioner, vs. HON. JUDGE JOSE C. CAMPOS, JR., NORA L. DE LEON, BERNARDO DE LEON, ARLENE DE LEON and IRMA L. VELOSO, respondents.

FACTS

Dr. Mariano M. Lazatin died intestate in 1974, survived by his widow, Margarita de Asis, and their two adopted daughters, respondents Nora L. de Leon and Irma L. Veloso. Margarita initiated intestate proceedings for her husband’s estate. Subsequently, Margarita herself died, leaving a holographic will. Petitioner Renato Lazatin initially intervened in Dr. Lazatin’s intestate proceedings, claiming to be an admitted illegitimate (not natural) son. Later, after Margarita’s death, petitioner sought to intervene in the probate of her will, this time asserting a new claim: that he was an adopted child of both deceased spouses. His claim was based primarily on an affidavit from Benjamin Lazatin, Dr. Lazatin’s brother, which was later modified to state petitioner was adopted by the couple.
The proceedings were complicated by respondent Nora L. de Leon’s opening of a joint safety deposit box after her mother’s death and removing its contents, which included the adoption papers of herself and her sister. The probate court eventually found her in contempt for failing to properly deliver these items to the court’s custody. Petitioner then filed a motion in the probate court, not merely to intervene, but to have the court declare as an established fact that he was the adopted son of the Lazatin spouses, based on the affidavit and alleged enjoyment of that status.

ISSUE

Whether the respondent judge correctly denied petitioner’s motion to have his status as an adopted child declared as an established fact in the estate proceedings without first requiring him to produce competent evidence of a final judicial decree of adoption.

RULING

Yes, the Supreme Court affirmed the respondent judge’s orders. The Court held that the establishment of a legal adoption, for purposes of succession, is governed by substantive law requiring a judicial decree. Petitioner’s claim of enjoying the status of an adopted child and his proffered affidavit are insufficient to prove a legal adoption absent the requisite final judgment from a competent court. The respondent judge correctly ruled that he could not allow petitioner to introduce evidence of enjoying adoptive status over the opposition of the legitimate heirs without petitioner first producing the judicial decree of adoption itself.
The legal logic is clear: adoption is a juridical act that creates a legal relationship of parent and child. Under the law in force at the time, this relationship could only be established through a judicial proceeding resulting in a final judgment. The Court emphasized that while facts of continuous possession of the status of a child may be relevant in certain cases (like filiation), they cannot substitute for the mandatory judicial decree required to establish adoption for succession purposes. Petitioner’s proper recourse, after his evidence was excluded, was to make a formal offer of proof and seek reversal on appeal from the final judgment in the estate proceedings, not through a special civil action. The petition was dismissed for lack of merit.