Case Summary (G.R. No. 212302)
Procedural History
• May 24, 2013: Petitioner filed before RTC Marikina a petition for judicial recognition of his Japanese adoption decree.
• November 21, 2013: RTC dismissed the petition as contrary to Philippine adoption laws and public policy; motion for reconsideration denied April 23, 2014.
• September 2, 2020: Supreme Court granted review on certiorari under Rule 45.
• September 26, 2022: Decision rendered reversing the RTC and remanding for further proceedings.
Facts
• Petitioner’s parents divorced in 1997; mother married Hayashi in 2002.
• At age 16, petitioner was adopted by Hayashi under Japan’s legal regime; this adoption was duly recorded in Hayashi’s Koseki.
• Petitioner, then 24, sought Spanish recognition in the Philippine civil registry to secure parental‐authority and succession rights locally.
Issue
Can a foreign adoption decree involving a Filipino adoptee and a foreign adoptive parent, valid under the latter’s national law and falling within exceptions of Philippine adoption statutes, be judicially recognized in the Philippines without violating domestic adoption legislation or public policy?
Applicable Law
• Constitution (1987), Art. 2(2): incorporates generally accepted principles of international law.
• Civil Code, Art. 15: nationality principle binds family‐law matters for Filipino citizens.
• Family Code (EO 209), Arts. 183–184: sets qualifications and exceptions for adopters; alien spouse of Filipino parent may adopt legitimate child of spouse.
• RA 8043 (Inter-Country Adoption Act of 1995): applies only to “legally free” children, not to adoptees already in parental relationship.
• RA 8552 (Domestic Adoption Act of 1998), Sec. 7(b)(ii): allows alien spouse of Filipino to adopt legitimate child of spouse.
• Rules of Court, Rule 39, Sec. 48: provides for recognition and effect of foreign judgments or final orders.
Analysis
- Nationality Principle vs. Territorial Principle
– Philippine adoption laws bind the Filipino adoptee; foreign adopter is governed by his national law. - Statutory Exceptions
– Family Code Art. 184(3)(b) and RA 8552 Sec. 7(b)(ii) expressly permit a foreign spouse of a Filipino to adopt the legitimate child of the Filipino spouse.
– RA 8043 does not apply because petitioner is not a “legally-free child” and because the Family Code exception exempts this scenario from inter‐country adoption rules. - Recognition of Foreign Judgments
– Section 48, Rule 39, embodies the generally accepted principle of comity: foreign final judgments are presumptively recognized, subject only to proof of extrinsic grounds for refusal (lack of jurisdiction, notice, fraud, public policy).
– Petitioner need only prove the Japanese court’s decree
Case Syllabus (G.R. No. 212302)
Facts of the Case
- Petitioner Karl William Yuta Magno Suzuki, born April 4, 1988 in Manila, is the natural son of Sadao Kumai Suzuki (Japanese national) and Lorlie Lopez Magno (Filipino citizen).
- His parents married on December 29, 1987 and divorced on June 12, 1997.
- Lorlie remarried Japanese national Hikaru Hayashi on December 6, 2002 in San Juan City, Metro Manila.
- On November 9, 2004, at age 16, petitioner was adopted by Hayashi under Japanese law; this adoption was recorded in Hayashi’s Koseki (Family Register).
- The Koseki and its English translation were authenticated by the Philippine Consulate General on May 15, 2007.
- On May 24, 2013, petitioner (then 24 years old) filed a Petition for Judicial Recognition of Foreign Adoption Decree with RTC Branch 192, Marikina City.
Procedural History
- June 4, 2013: RTC required the Office of the Solicitor General (OSG) to comment on the petition.
- November 4, 2013: OSG filed its comment/opposition, arguing that Philippine adoption laws (EO 91, Family Code, RA 8043, RA 8552) govern all adoptions of Filipino citizens and that foreign adoptions not made under these statutes should not be recognized.
- November 21, 2013: RTC dismissed the petition as “contrary to law and public policy.”
- RTC denied petitioner’s motion for reconsideration on April 23, 2014, reiterating that foreign adoption decrees require a “judgment or final order of a tribunal of a foreign country,” which petitioner failed to present.
- August 7, 2017: Supreme Court required memoranda. Petitioner and OSG submitted their respective memoranda.
- Petitioner directly filed the petition for review on certiorari under Rule 45, raising pure questions of law.
Issues Presented
- Whether Philippine courts may judicially recognize a foreign decree of adoption involving a Filipino citizen when the decree