Diwata Ramos Landingin v. Republic

Summary

Diwata Ramos Landingin, a US citizen residing in Guam, sought to adopt three minor children who are her deceased brother's children. The RTC granted the adoption, but the Court of Appeals reversed, citing lack of proper consent from the biological mother and authentication issues. The Supreme Court affirmed the reversal, emphasizing that written consent of biological parents is mandatory under RA 8552, abandonment was not proven since the mother maintained minimal contact and financial support, the consent from petitioner's children was improperly authenticated, and petitioner's limited financial capacity as a part-time worker raised concerns about her ability to support the children. The decision reinforces that while adoption laws are construed liberally to serve children's best interests, strict compliance with procedural requirements remains essential, particularly regarding parental consent and adopter qualifications.