Short answer. The old Civil Code line answering this question is no longer reliable on its own: adoption and the successional consequences that flow from it are now governed by Republic Act No. 8552 and, since 2022, Republic Act No. 11642, not by this 1950 provision, so its exclusion of adoptive parents should not be treated as the current rule.
What the law says
In case of the death of an adopted child, leaving no children or descendants, his parents and relatives by consanguinity and not by adoption, shall be his legal heirs.
Civil Code, Article 984 — Death of an Adopted Child. Read the full provision →
What the 1950 text says
As written, Article 984 of the Civil Code provides that if an adopted child dies leaving no children or descendants, the heirs are his parents and relatives by consanguinity and not by adoption. Read on its own, that sentence points the inheritance back toward the biological family and away from the adoptive parents entirely, treating the adoptive relationship as if it had no bearing on this succession at all.
Why that answer is not the whole picture today
Adoption is no longer governed by the Civil Code. Republic Act No. 8552, the Domestic Adoption Act of 1998, and, since 2022, Republic Act No. 11642, which set up an administrative process for domestic adoption, now govern adoption and the successional consequences that follow from it. Article 984 has to be read subject to those later statutes rather than applied as if adoption law had stood still since 1950.
What this page can and cannot tell you
This page draws only from the Civil Code article itself, and that article does not reflect the current statutory framework on adoption. It would be misleading to present its exclusion of adoptive parents as settled law today. Whether adoptive parents have a successional claim in this situation is a question that has to be answered by looking at RA 8552 and RA 11642 directly, not by this superseded provision.
The practical takeaway
If you are facing this exact situation, do not assume the Civil Code's old line — biological family only, never the adoptive parents — is still good law. Treat it as an open question that turns on the current adoption statutes rather than on this 1950 article, and confirm the answer under those laws before relying on any inheritance outcome. A page repeating the old exclusion as settled fact would be doing the reader a disservice.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Bernardina P. Bartolome vs. Social Security System and Scanmar Maritime Services, Inc, G.R. No. 192531, November 12, 2014 — read the decision on LawPhil →