A.M. No. P-05-2017 - Lopez vs. Ramos

Rosario Mata Castro and Jose G. Castro were married on August 5, 1962 in Laoag City; their first child died shortly after birth in 1963.
They separated a few months after marriage, reconciled in 1969, had a second child (Joanne) in 1970, then permanently separated due to incompatibility and alleged homosexual tendencies of Jose.

On August 1, 2000, Jose filed a petition in RTC Batac, Ilocos Norte to adopt his two illegitimate children—Jose Maria Jed Lemuel Gregorio (b. 1987) and Ana Maria Regina Gregorio (b. 1989)—born of Lilibeth Fernandez Gregorio.
The Home Study Report described Jose’s age (70), family prominence, his legal career, Lilibeth’s death in 1995, and his intention “to legalize their relationship and surname.”
The trial court approved the adoption on October 16, 2000, noting “no opposition … from any person,” and a certificate of finality issued on February 9, 2006.

Rosario and Joanne learned of the adoption only in 2005; Rosario filed a disbarment complaint against Jose in July 2006. Jose died in October 2006.
On October 18, 2007, Rosario and Joanne filed a petition for annulment of judgment under Rule 47 before the Court of Appeals, alleging lack of notice, fraudulent consent affidavit, conflicting birth certificates, and non-inclusion of indispensable parties.
The Court of Appeals denied the petition on May 26, 2009, ruling no personal-service requirement for spouses and legitimate children and classifying the alleged fraud as intrinsic. Reconsideration was denied on July 10, 2009.

Whether the Court of Appeals erred in finding that petitioners failed to show the trial court lacked jurisdiction over the adoption proceedings.
Whether the Court of Appeals erred in ruling that petitioners failed to establish extrinsic fraud warranting annulment of judgment.