G.R. No. 135385 - Cruz vs. Secretary of Environment and Natural Resources

The case involves a petition for a writ of habeas corpus filed on behalf of minor Angelie Anne Cervantes.
The minor was born on February 14, 1987, to respondents Gina Carreon and Conrado Fajardo.
Respondents, who were in a common-law relationship—with Conrado Fajardo being legally married to another woman—became involved in adoption proceedings concerning the child.

Respondents offered the child for adoption to petitioners Zenaida Carreon-Cervantes and Nelson Cervantes, who are the sister and brother-in-law of Gina Carreon.
An affidavit of consent for the child’s adoption was executed by Gina Carreon on April 29, 1987.
Petitioners filed the appropriate petition for adoption (Sp. Proc. No. 057-B) before the Regional Trial Court of Rizal, Fourth Judicial District, Branch 67.
On August 20, 1987, the court granted the petition, ordering that the child be legally freed from the parental authority of her natural parents and be known henceforth as Angelie Anne Cervantes.
Through the adoption decree, full parental rights and custody were conferred upon the petitioners.

Shortly after the adoption order, respondents—specifically Gina Carreon—demanded a sum of P150,000.00 from the petitioners, threatening to reclaim the child if the demand was not met.
Petitioners refused to accede to the monetary demand.
On September 11, 1987, while the petitioners were away at work, Gina Carreon removed the minor from the petitioners’ residence in Angono, Rizal, under the pretense of following instructions from her own mother.
The child was taken to Gina Carreon’s house in Parañaque, further complicating the custody issue.

Felisa Tansingco, the social worker who conducted the case study on the adoption, testified on October 27, 1987, before the Executive Judge, Regional Trial Court of Pasig.
According to her testimony, during an interview on June 24, 1987, Gina Carreon had clearly manifested her desire for the child to be adopted by the petitioners.
The testimony and the affidavit of consent play a pivotal role in establishing that the adoption process was executed with the requisite consent and understanding (despite later claims of inadequate explanation).

It was undisputed that Conrado Fajardo, although involved in the adoption process, is legally married to another woman, which questions the stability of a common-law household for the minor.
Gina Carreon’s history—including giving birth to another child with a different, married man—raised concerns about her ability to provide a stable and morally proper environment for Angelie Anne.
Petitioners, being legally married, were evaluated as morally, physically, financially, and socially capable of offering the minor a better environment conducive to her growth and development.

Whether the affidavit of consent executed by Gina Carreon, despite later claims that its implications were not fully explained to her, sufficiently validated the adoption process.
Whether the legal effect of the adoption decree automatically dissolves the parental authority of the natural parents, thereby vesting full custody in the petitioners.

Whether the act of removing the minor from her adoptive home by Gina Carreon constitutes an unlawful detainment and a violation of the adopted legal order.
Whether the petition for a writ of habeas corpus is justified based on the discrepancy between the legal adoption order and the actions taken by the respondent.

Given the conflicting environments presented by the natural and adoptive parents, which arrangement best serves the welfare and moral development of the minor.
Whether the custodial environment provided by the petitioners outweighs the familial ties and claims of the respondents.