G.R. No. L-4811 - Woodhouse vs. Halili

Petitioner-appellant Leouel Santos, Sr., an army lieutenant, and respondent Julia Bedia, a nurse, were married in Iloilo City in 1986.
They had one child, Leouel Santos, Jr., born on July 18, 1987.
From the time of the child's release from the hospital, he was placed in the temporary custody of his maternal grandparents, respondents Leopoldo and Ofelia Bedia, by mutual agreement of the parents.

The maternal grandparents claimed to have paid for the hospital bills and supported the child because petitioner could not afford it.
Julia Bedia-Santos left for the United States in May 1988 for work, and the petitioner allegedly lost contact with her despite efforts to locate her.
The grandparents asserted that Julia sent financial support for the child through them.
On September 2, 1990, petitioner and his brothers visited the grandparents' residence and allegedly abducted the three-year-old child through deceit and without permission.

Spouses Bedia filed a Petition for Care, Custody, and Control of Minor Leouel Santos Jr. before the Regional Trial Court (RTC) of Iloilo City, Branch 29, with petitioner as respondent.
After an ex-parte hearing on October 8, 1990, the RTC awarded custody of the child to the grandparents.
Petitioner appealed to the Court of Appeals, which affirmed the RTC’s decision on April 30, 1992.
Petitioner's motion for reconsideration was denied on November 13, 1992.
Petitioner filed the present petition for review challenging the appellate court’s decision.

Petitioner contended that he was the natural and legal custodial parent and that private respondents failed to prove his unfitness. He argued that substitute parental authority under Article 214 of the Family Code applies only when both parents are dead, absent, or unsuitable.
The grandparents argued they could better provide for the boy’s needs, including financial and medical care. They claimed petitioner had not supported the child and that his military duties would prevent him from attending properly to the boy’s welfare.
They also argued that petitioner’s abduction of the child demonstrated unfitness and that their love and devotion placed them in the best position to care for the boy.

Whether or not petitioner, as the natural father, is entitled to the custody of his minor son, Leouel Santos, Jr., over the custody claimed by the maternal grandparents.
Whether the award of custody to the grandparents under Article 214 of the Family Code is proper in the absence of demonstrated parental unfitness, death, or absence.