Masbate v. Relucio

Summary

This child custody case involves 3-year-old illegitimate child Queenie, whose parents Renalyn (mother) and Ricky James (father) disputed custody after their relationship ended. When Renalyn's parents took Queenie using a power of attorney while Renalyn studied in Manila, Ricky James filed habeas corpus seeking custody. The RTC dismissed the petition citing the tender-age presumption favoring mothers. The CA remanded for trial and granted temporary custody to the father. The Supreme Court affirmed the remand but deleted temporary custody, holding that while illegitimate children are under maternal authority, fathers as actual custodians can seek custody if mothers are proven unfit through proper trial, with the child's best interests paramount. The case establishes that tender-age presumption applies regardless of legitimacy status and that actual custodians have standing in custody disputes.