LIMITED JURISDICTION OF PROBATE COURT

ANA JOYCE S. REYES, Petitioner,

vs.
HON. CESAR M. SOTERO, Presiding Judge, RTC of Paniqui, Tarlac, Branch 67, ATTY.
PAULINO SAGUYOD, the Clerk of Court of Branch 67 of the RTC at Paniqui, Tarlac in
his capacity as Special Administrator, CORAZON CHICHIOCO, ANGELITO LISING,
ERLINDA ESPACIO, GONZALO ZALZOS and ERNESTO LISING, Respondents.
FACTS:
CORAZON CHICHIOCO, respondent, filed a petition for the issuance of letters of
administration and settlement of estate claiming that she is the niece and heir of
the late Elena Lising who died intestate. Chichioco prayed that she be appointed
administrator of the estate, upon payment of a bond, pending settlement and
distribution of Lisings properties to the legal heirs. In her petition, she alleges that
the deceased left real properties as well as assorted pieces of jewelry and cash
which was supposedly in the possession of ANA REYES, petitioner. CHICHIOCO also
alleged that the other private respondents as co-heirs.
In her Opposition, REYES, asks that the case be dismissed since she is the adopted
child of the Sps. Delos Santos and thus the rightful heir. She presented the
certification issued by the Municipal Registrar where her adoption decree was
registered as well as a Judicial form and certification from the Clerk of Court of the
RTC which decreed her adoption.
The decree of adoption and the certification presented were contested by the
respondents alleging fraud and falsification of documents. Consequently, Chichioco
and her alleged co-heirs filed before the Court of Appeals a petition for annulment
of the adoption decree. CA refrained from dismissing the petition for letters of
administration and settlement of estate on the ground that petitioner must first
prove that she was legally adopted by the decedent, Elena Lising. CA ordered REYES
to prove before the trial court the authenticity of her adoption since imputations of
irregularities has cast a cloud of doubt on the authenticity of her the adoption
decree. REYES filed a MR which was denied, hence this petition.
ISSUE: WON the adoption decree can be assailed in a proceeding for the settlement
of the decedents estate
HELD:
NO. The presentation of contrary proof to nullify the adoption decree should be
presented in a separate action. The adoption decree cannot be assailed collaterally
in the proceeding for the settlement of a decedents estate. Respondents cannot
assail in these proceedings the validity of the adoption decree in order to defeat

petitioners claim that she is the sole heir of the decedent. Absent a categorical
pronouncement in an appropriate proceeding that the decree of adoption is void,
the certifications regarding the matter, as well as the facts stated therein, should be
deemed legitimate, genuine and real. Petitioners status as an adopted child of the
decedent remains unrebutted and no serious challenge has been brought against
her standing as such. Therefore, for as long as petitioners adoption is considered
valid, respondents cannot claim any interest in the decedents estate.