Under Article 341 of the New Civil Code, upon the adoption of a child, he/she shall, among others,

have the same rights and duties as if he were a legitimate child of the adopter and be a legal heir of the adopter. However, nothing in the law provides for the right of the adopted child to inherit from the legitimate child of the adopting parent. However in a number of cases, it has been held that the relationship established by reason of the adoption does not extend to the other relatives of the adopter. In other words, the relationship established by the adoption is limited to the adopting parent. Thus, the adopted child cannot be considered as a relative of the ascendants and collaterals of the adopting parents, nor of the legitimate children which they may have after the adoption, except that the law imposes certain impediments top marriage by reason of adoption. The relationship created is exclusively between the adopter and the adopted, and does not extend to the relatives of either. (page 704 of paras) Under Article 345, the proceedings for adoption shall be governed by the Rules of Court insofar as they are not in conflict with this Code. It was held in the case of Yigo, et al. vs. Republic that the only valid adoption in the Philippines is that one made through the court. While in the case of Lazatin vs. Hon Judge Campos, it was held that adoption is a juridical act, a proceeding in rem which creates between two persons a relationship similar to that which results from legitimate paternity and filiation. Only an adoption made through the court, or in pursuance with the procedure laid down under Rule 99 of the Rules of Court is valid in this jurisdiction. It is not of natural law at all, but is wholly and entirely artificial. To establish the relation, the statutory requirements must be strictly carried out, otherwise, the adoption is an absolute nullity. The fact of adoption is never presumed, but must be affirmatively proved by the person claiming its existence. The destruction by fire of a public building in which the adoption papers would have been filed if existent does not give rise to a presumption of adoption nor is the destruction of the records of an adoption proceeding to be presumed. On the contrary, the absence of a record of adoption has been said to evolve a presumption of its non-existence. Where, under the provisions of the statute, an adoption is effected by a court order, the records of such court constitute the evidence by which such adoption may be established.