Case Digest (G.R. No. 212302) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Karl William Yuta Magno Suzuki a.k.a. Yuta Hayashi v. Office of the Solicitor General, G.R. No. 212302, petitioner was born on April 4, 1988 in Manila to a Japanese father and a Filipino mother. His parents married in December 1987 and divorced on June 12, 1997. On December 6, 2002, his mother wed Japanese national Hikaru Hayashi. On November 9, 2004, at age sixteen, petitioner was adopted by Hayashi under Japanese law, an event recorded in Hayashi’s *Koseki* (Family Register) and authenticated by the Philippine Consulate on May 15, 2007. Seeking to recognize this foreign adoption in the Philippines, petitioner filed on May 24, 2013 a Petition for Judicial Recognition of Foreign Adoption Decree before Branch 192, RTC Marikina City (JDRC Case No. 2013-2279-MK). The Office of the Solicitor General opposed, invoking Executive Order 91, the Family Code, RA 8043 (Inter-Country Adoption Act), and RA 8552 (Domestic Adoption Act). The RTC, in an order dated November 21, 2013 (Judge G Case Digest (G.R. No. 212302) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petitioner’s Personal and Family Background
- Karl William Yuta Magno Suzuki a.k.a. Yuta Hayashi born April 4, 1988 in Manila to Sadao Kumai Suzuki (Japanese) and Lorlie Lopez Magno (Filipino).
- Parents married December 29, 1987; divorced June 12, 1997; mother married Hikaru Hayashi (Japanese) on December 6, 2002.
- Japanese Adoption Proceedings
- On November 9, 2004, 16-year-old petitioner was adopted by Hayashi under Japanese law and entered in Hayashi’s Koseki (Family Register).
- Koseki and English translation authenticated by Philippine Consulate General on May 15, 2007; petitioner confirmed Filipino citizen by Bureau of Immigration ID Certificate No. 08-19540 (March 31, 2008).
- Philippine Judicial Recognition Proceedings
- May 24, 2013 – petitioner filed Petition for Judicial Recognition of Foreign Adoption Decree before RTC-Marikina.
- June 4, 2013 – RTC required OSG comment; November 4, 2013 – OSG opposed, citing EO 91, Family Code, RA 8043 and RA 8552.
- November 21, 2013 – RTC dismissed petition as contrary to law and public policy; April 23, 2014 – Motion for Reconsideration denied.
- September 2, 2020 – petitioner filed Rule 45 petition before Supreme Court; parties submitted memoranda.
Issues:
- Whether a foreign decree of adoption of a Filipino citizen by an alien spouse may be judicially recognized in the Philippines.
- Whether petitioner’s Japanese adoption by his stepfather Hayashi complies with Philippine adoption laws for recognition.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)