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Isabelita S.

Lahom
vs.
Jose Melvin Sibulo

Isabelita S. Lahom - petitioner


Jose Melvin Sibulo - respondent
Ponente: Justice Vitug
Facts:
A couple. Dr. Diosdado and Isabelita Lahom decided to adopt Isabelitas nephew, Jose
Melvin Sibulo to bring him up as their own child. They filed an adoption decree on the civil registrar
of Naga City which was granted and changed the name of Jose Melvin Sibulo to Jose Melvin Lahom.
In a sad turn of events, Mrs. Lahom being a widow and suffering for a leg ailment filed a petition to
the lower court of Naga to annul the adoption decree on the ground that the attitude of her
adopted son was not expected of him and he does not care for her health and welfare. The latter
also refused to use the name of Lahom and instead continue using Sibulo in connection to his
practice of profession. It was also found out that the motive of the adopted son for adoption was
his rights to the property of his mother and father. Melvin Sibulo opposing and moved for the
dismissal of the petition filed by his mother was granted by the lower court by dismissing the
petition of the petitioner. Insisting on her rights, Mrs. Lahom filed a petition for a review in the
Supreme Court.
Issue:
Whether the decree of adoption could still be revoked/annulled by the adopter even after
the effectivity of R.A. 8552.
Decision:
No. it was months after the effectivity of R.A. 8552. that Mrs. Lahom filed an action to annul
the decree of adoption. The new law had already been abrogated and repealed. For valid reasons
it can cause the forfeiture of certain benefits if the child is undeserving.