Facts:

• Renato Lazatin, also known as Renato Sta. Clara, is the petitioner against Judge Jose C. Campos, Jr. and private respondents Nora L. de Leon, Bernardo de Leon, Arlene de Leon, and Irma L. Veloso.
• Dr. Mariano M. Lazatin passed away on January 13, 1974, in Pasay City, survived by his wife Margarita de Asis and their adopted twin daughters.
• Margarita initiated intestate proceedings for Dr. Lazatin's estate but died a month later, leaving a holographic will with legacies.
• Five days after Margarita's death, Nora L. de Leon accessed a safety deposit box belonging to her mother, claiming good faith; the box contained various items, including adoption papers.
• After the box was found empty, Ramon Sta. Clara, the petitioner's son, filed a motion to examine its contents.
• Renato later intervened in the estate proceedings, claiming to be an adopted child based on an affidavit from Benjamin Lazatin, the deceased's brother.
• The court ruled against Renato, stating he failed to provide competent evidence of his adoption, leading to the current petition.

Issue:

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Ruling:

• The Supreme Court upheld the respondent judge's ruling that the petitioner failed to establish his status as an adopted child.
• The evidence presented by the petitioner was deemed insufficient to prove his claim of adoption.
• The petition...(Unlock)

Ratio:

• The Supreme Court emphasized that adoption is a legal act requiring establishment through judicial proceedings, as per Rule 99 of the Rules of Court.
• The burden of proof lies with the person claiming adoption, and such status cannot be presumed.
• The absence of a judicial decree of adoption or competent ev...continue reading