Tag: DSWD

  • Senior Citizen Discounts: When Do Golf Clubs Have to Comply?

    Senior Citizen Discounts: When Do Golf Clubs Have to Comply?

    HON. CORAZON J. SOLIMAN VS. CARLOS T. SANTOS, G.R. No. 202417, July 25, 2023

    Imagine a senior citizen looking forward to a relaxing day at the golf club, only to be denied the discounts they’re entitled to under the law. This scenario highlights a common point of confusion: do private golf clubs have to offer senior citizen discounts? The Supreme Court recently tackled this issue, clarifying the scope of the Expanded Senior Citizens Act of 2010 (RA 9994) and its implications for recreational facilities.

    This case revolves around Carlos T. Santos, Jr., a senior member of The Manila Southwoods Golf and Country Club, Inc., who requested the 20% senior citizen discount on his monthly dues, locker rentals, and other fees. The club refused, citing an implementing rule that exempts non-profit, stock golf and country clubs. The central legal question is whether this implementing rule is valid, or if it contradicts the law it’s supposed to enforce.

    The Legal Framework: Senior Citizen Discounts and Administrative Rules

    The Expanded Senior Citizens Act of 2010 (RA 9994) grants senior citizens several privileges, including a 20% discount and VAT exemption on certain goods and services. Section 4(a)(7) specifically mentions “the utilization of services in hotels and similar lodging establishments, restaurants, and recreation centers.” This provision seems straightforward, but the devil is in the details – or, in this case, the implementing rules and regulations (IRR) issued by the Department of Social Welfare and Development (DSWD).

    The IRR attempted to clarify the scope of “recreation centers” by stating that non-profit, stock golf and country clubs that are private and for exclusive membership are not mandated to give the 20% senior citizen discount. This is the provision that was challenged in this case.

    It’s important to understand that an IRR cannot expand or restrict the law it implements. The Supreme Court has consistently held that administrative rules and regulations must conform to the law, carry its general policies into effect, and not contravene the Constitution or other laws. As the Supreme Court stated in this case, “In case of conflict between the law and the IRR, the law prevails. There can be no question that an IRR or any of its parts not adopted pursuant to the law is no law at all and has neither the force nor the effect of law.”

    To illustrate, imagine a law that requires all restaurants to offer a senior citizen discount. An IRR cannot then say that only restaurants with a certain seating capacity must comply. That would be an invalid restriction of the law’s coverage.

    Case Breakdown: Santos vs. Manila Southwoods

    Carlos T. Santos, Jr., feeling shortchanged, filed a complaint with the Regional Trial Court (RTC) to invalidate the IRR provision. He argued that it contradicted the clear language of RA 9994.

    The RTC sided with Santos, declaring the IRR provision invalid. The court emphasized that RA 9994 grants a 20% discount to senior citizens for recreation centers, and the law doesn’t distinguish between public and private establishments. The RTC stated that “the language of the law is clear, plain and unequivocal.”

    The DSWD and Manila Southwoods appealed, arguing that the IRR provision was a valid clarification of the law’s intent. The case eventually reached the Supreme Court, which consolidated the two petitions.

    The Supreme Court’s decision hinged on whether the IRR provision was consistent with RA 9994. The Court noted that the law provides a 20% discount to senior citizens on the sale of goods and services from all establishments without any proviso allowing the DSWD to create blanket exceptions. The Court stated, “To recall, Sec. 4(a), RA 9994, provides a 20% discount to senior citizens on the sale of the enumerated goods and services from all establishments… Moreover, Sec. 4(a)(7) provides that this discount applies to ‘the utilization of services in hotels and similar lodging establishments, restaurants and recreation centers,’ and does not allow the DSWD to exempt entire classes of recreation centers from the coverage of this discount.”

    The Supreme Court ultimately ruled that the DSWD exceeded its authority in creating the exemption for private golf clubs. However, the Court clarified an important distinction: the 20% discount applies to the sale of services, but not to membership dues.

    Practical Implications: What This Means for Golf Clubs and Senior Citizens

    This ruling has significant implications for both golf clubs and senior citizens. Golf clubs cannot deny senior citizen discounts on services like locker rentals, golf cart usage, and other fees for using the facilities. However, they are not required to discount membership dues, as these are considered payments for the privilege of membership, not the sale of a service.

    For example, if a senior citizen pays P500 for a round of golf using a golf cart, they are entitled to a P100 discount. But if their monthly membership dues are P2,000, that amount is not subject to the discount.

    Key Lessons:

    • IRRs cannot contradict or expand the law they implement.
    • Senior citizen discounts apply to the sale of services in recreation centers, but not to membership dues.
    • Golf clubs must comply with RA 9994 for services offered to senior citizen members.

    Frequently Asked Questions

    1. Does this ruling apply to all private clubs, not just golf clubs?

    The ruling specifically addresses golf clubs, but the principle applies to other private clubs offering services to members. The key is whether a service is being sold, as opposed to a membership privilege.

    2. What if a golf club claims its membership dues cover all services?

    The club needs to clearly delineate the cost of membership versus the cost of specific services. If a separate fee is charged for a service, it is likely subject to the discount.

    3. Can a golf club increase its fees to offset the cost of the discount?

    While clubs are free to adjust their pricing, they cannot do so in a discriminatory manner specifically targeting senior citizens.

    4. What should a senior citizen do if a club refuses to grant the discount?

    The senior citizen can file a complaint with the DSWD or seek legal assistance to enforce their rights.

    5. Does this ruling apply retroactively?

    Generally, court decisions apply prospectively, meaning they affect cases going forward, not past transactions.

    6. Are there any exceptions to this ruling?

    The ruling focuses on the distinction between membership dues and fees for services. Any other exceptions would need to be based on specific provisions of RA 9994 or other relevant laws.

    ASG Law specializes in regulatory compliance and senior citizen rights. Contact us or email hello@asglawpartners.com to schedule a consultation.

  • Writ of Amparo: Not a Substitute for Child Custody Disputes

    The Supreme Court has clarified that a petition for a writ of amparo is not the appropriate legal remedy for resolving child custody disputes. The writ of amparo is designed to address extrajudicial killings and enforced disappearances, or threats thereof. In cases involving parental rights and child custody, other legal remedies, such as civil cases under the Family Code or petitions for habeas corpus, are more appropriate. This distinction ensures that the writ of amparo is reserved for the urgent and grave situations it was intended to address, while allowing family law matters to be resolved through established legal procedures.

    When a Mother’s Plea for Custody Misses the Mark: Understanding the Amparo Rule

    This case revolves around Ma. Christina Yusay Caram, who initially surrendered her child, Baby Julian, for adoption but later sought to regain custody. After Marcelino, the child’s father, passed away, Christina filed a petition for a writ of amparo, claiming that the Department of Social Welfare and Development (DSWD) had unlawfully deprived her of her parental rights and caused the “enforced disappearance” of her child. The Regional Trial Court (RTC) dismissed the petition, holding that a writ of amparo was not the proper remedy. Christina elevated the case to the Supreme Court, questioning the constitutionality of Republic Act (R.A.) No. 9523 and seeking the return of her child through the amparo proceedings. The Supreme Court then had to determine whether the writ of amparo was the appropriate legal tool to address a dispute centered on parental authority and child custody.

    The Supreme Court anchored its decision on the explicit scope of the Rule on the Writ of Amparo. Section 1 of the Rule clearly states that the writ is available to individuals whose right to life, liberty, and security is violated or threatened by an unlawful act or omission by a public official, employee, or private individual. The key, however, is that the writ specifically targets extralegal killings and enforced disappearances, or threats thereof. The Court, citing Secretary of National Defense, et al. v. Manalo, et al., emphasized that the Amparo Rule was created to address the critical problems of “extralegal killings” and “enforced disappearances.”

    [T]he Amparo Rule was intended to address the intractable problem of “extralegal killings” and “enforced disappearances,” its coverage, in its present form, is confined to these two instances or to threats thereof. “Extralegal killings” are “killings committed without due process of law, i.e., without legal safeguards or judicial proceedings.” On the other hand, “enforced disappearances” are “attended by the following characteristics: an arrest, detention or abduction of a person by a government official or organized groups or private individuals acting with the direct or indirect acquiescence of the government; the refusal of the State to disclose the fate or whereabouts of the person concerned or a refusal to acknowledge the deprivation of liberty which places such persons outside the protection of law.

    Building on this principle, the Court referenced Lozada, Jr. v. Macapagal-Arroyo, which explicitly confined the writ of amparo to cases of extrajudicial killings and enforced disappearances. Further, in Navia v. Pardico, the elements constituting “enforced disappearances” were enumerated based on Section 3(g) of R.A. No. 9851:

    (a) that there be an arrest, detention, abduction or any form of deprivation of liberty;
    (b) that it be carried out by, or with the authorization, support or acquiescence of, the State or a political organization;
    (c) that it be followed by the State or political organization’s refusal to acknowledge or give information on the fate or whereabouts of the person subject of the amparo petition; and,
    (d) that the intention for such refusal is to remove subject person from the protection of the law for a prolonged period of time.

    The Court found that Christina’s claims did not align with the definition of “enforced disappearance” under the Amparo Rule. The DSWD officers never concealed Baby Julian’s location; Christina herself had a copy of the DSWD’s memorandum indicating that Baby Julian was in the custody of the Medina Spouses. Additionally, Baby Julian was presented before the RTC during a hearing. Thus, the critical elements of concealment and refusal to acknowledge the child’s whereabouts were absent, negating any claim of “enforced disappearance.” The Court emphasized that Christina’s petition was essentially an assertion of her parental authority and a contestation of custody, rather than a search for a missing child. The Supreme Court then explained why the Amparo rule was unsuitable.

    In essence, the Supreme Court underscored that the writ of amparo is not a tool for resolving custody disputes. It is a remedy designed to protect individuals from extrajudicial killings and enforced disappearances, ensuring their right to life, liberty, and security. Christina’s situation, while undoubtedly emotional and legally complex, did not fall within the scope of the Amparo Rule. Instead, the proper course of action would involve pursuing remedies available under the Family Code or seeking a writ of habeas corpus if there were allegations of illegal detention. Ultimately, the Supreme Court affirmed the RTC’s decision, denying the petition for a writ of amparo.

    FAQs

    What was the key issue in this case? The key issue was whether a petition for a writ of amparo is the proper legal remedy for obtaining parental authority and custody of a minor child. The Supreme Court ruled that it is not.
    What is the writ of amparo intended for? The writ of amparo is intended to address extrajudicial killings and enforced disappearances, or threats thereof. It is designed to protect the right to life, liberty, and security of individuals facing such grave violations.
    What are the elements of “enforced disappearance” as defined by law? The elements include an arrest, detention, abduction, or any form of deprivation of liberty carried out by the State or with its acquiescence, followed by a refusal to acknowledge or provide information on the person’s fate or whereabouts, with the intent to remove them from legal protection for a prolonged period.
    Why was the writ of amparo not applicable in this case? The writ was not applicable because the DSWD officers did not conceal the child’s whereabouts, and the mother’s petition was essentially a dispute over custody and parental rights, not a case of enforced disappearance.
    What legal remedies are available for resolving child custody disputes? Legal remedies available for resolving child custody disputes include civil cases under the Family Code and, in cases of illegal detention, petitions for habeas corpus.
    What did the Supreme Court decide in this case? The Supreme Court denied the petition for a writ of amparo, affirming the RTC’s decision that the writ was not the proper remedy for resolving a child custody dispute.
    What is the significance of the ruling in this case? The ruling clarifies the scope and limitations of the writ of amparo, ensuring that it is reserved for the urgent and grave situations it was intended to address and preventing its misuse in family law matters.
    What was the mother’s claim in filing the petition for amparo? The mother claimed that the DSWD officers caused her “enforced separation” from her child and that their actions amounted to an “enforced disappearance” within the context of the Amparo rule.

    This case serves as a clear reminder that legal remedies must be appropriately matched to the specific nature of the grievance. While the desire to reunite with a child is deeply personal and compelling, the writ of amparo is not a substitute for established legal procedures designed to address family law matters. The Supreme Court’s decision underscores the importance of adhering to the intended scope of legal remedies to ensure their effectiveness in protecting fundamental rights.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: INFANT JULIAN YUSAY CARAM, REPRESENTED BY HIS MOTHER, MA. CHRISTINA YUSAY CARAM VS. ATTY. MARIJOY D. SEGUI, ET AL., G.R. No. 193652, August 05, 2014

  • Rehabilitation and Reintegration: The Court’s Role in Juvenile Offender Cases

    In People v. Candelario and Legarda, the Supreme Court addressed the process for reintegrating youthful offenders back into society after rehabilitation. The Court clarified that while the Department of Social Welfare and Development (DSWD) plays a crucial role in rehabilitating juvenile offenders, the final decision regarding their release and reintegration rests with the trial court. This ensures a judicial review of the DSWD’s recommendation, balancing the offender’s progress with public safety and the fulfillment of any civil liabilities. The case underscores the importance of a holistic approach to juvenile justice, emphasizing rehabilitation, accountability, and judicial oversight.

    From Conviction to Rehabilitation: Who Decides a Youthful Offender’s Fate?

    The case stemmed from the conviction of Ludigario Candelario and Gerry Legarda for Robbery with Multiple Rape. While Candelario faced the death penalty, Legarda, being a youthful offender, was sentenced to reclusion perpetua. Following the finality of the decision, the DSWD submitted a Final Report, highlighting Legarda’s positive progress and recommending his transfer to his father’s custody. This prompted the Supreme Court to examine the proper procedure for handling such recommendations, especially concerning youthful offenders who have undergone rehabilitation.

    The core legal issue revolves around the interpretation of Presidential Decree No. 603, also known as the Child and Youth Welfare Code, particularly Article 196, which discusses the dismissal of a case against a youthful offender. The DSWD’s recommendation for dismissal and discharge raised the question: Does a favorable report from the DSWD automatically warrant the release of a youthful offender? The Supreme Court, drawing from its previous ruling in People v. Ricky Galit, et al., clarified the roles of the DSWD and the trial court in these situations.

    In People v. Galit, the Court emphasized that it is not the sole responsibility of the Supreme Court to order the release of an accused without a review of the DSWD’s recommendation by the trial court. The High Court cited Article 196 of P.D. 603, which states:

    “Art. 196. Dismissal of the case. – If it is shown to the satisfaction of the court that the youthful offender whose sentence has been suspended, has behaved properly and has shown his capability to be a useful member of the community, even before reaching the age of majority, upon recommendation of the Department of Social Welfare, it shall dismiss the case and order his final discharge.”

    Building on this principle, the Court in People v. Candelario and Legarda reiterated that the trial court plays a crucial role in reviewing the DSWD’s recommendation. This review ensures that the court independently assesses whether the youthful offender has indeed been rehabilitated and is prepared to reintegrate into society. The court’s assessment should not be based solely on the DSWD’s conclusions but should involve a thorough examination of concrete, material, and relevant facts.

    The Court’s reasoning underscores the importance of judicial oversight in cases involving youthful offenders. While the DSWD’s expertise in rehabilitation is valuable, the trial court serves as a safeguard, ensuring that the offender’s release aligns with the interests of justice and public safety. This approach contrasts with a purely administrative process, where the DSWD’s recommendation would be automatically implemented without judicial scrutiny.

    The decision highlights the delicate balance between rehabilitation and accountability. While the law aims to provide youthful offenders with opportunities for reform, it also recognizes the need to protect society from potential harm. The trial court’s review process ensures that both of these considerations are taken into account before a youthful offender is released. The court also gives consideration to the youthful offenders civil liabilities that may have been incurred by the reason of his conviction.

    The practical implications of this ruling are significant. It clarifies the procedure for handling DSWD recommendations for the release of youthful offenders, ensuring that trial courts play an active role in the decision-making process. This provides a layer of protection for the community, as the court can independently assess the offender’s readiness for reintegration. The ruling also reinforces the importance of comprehensive rehabilitation programs that address the offender’s intellectual, physical, moral, and emotional well-being, as demonstrated by Legarda’s progress in the DSWD’s care.

    The importance of due process and judicial review in cases involving youthful offenders cannot be overstated. By requiring trial courts to independently assess the DSWD’s recommendations, the Supreme Court safeguards against arbitrary or premature release. This process ensures that the offender’s progress is carefully evaluated, and that any potential risks to public safety are properly addressed. The review of concrete facts as mandated by the court, is also essential. The court will need to consider the totality of circumstances that will lead to a conviction.

    FAQs

    What was the key issue in this case? The key issue was determining the proper procedure for releasing a youthful offender after the DSWD recommends their discharge following a period of rehabilitation.
    What did the DSWD recommend? The DSWD submitted a Final Report recommending that Gerry Legarda, a youthful offender, be released from their custody and transferred to his father’s care due to his positive rehabilitation progress.
    What did the Supreme Court decide? The Supreme Court directed the Regional Trial Court of Roxas City to review the DSWD’s recommendation and make its own judgment on whether Legarda should be released.
    Why didn’t the Supreme Court directly order Legarda’s release? The Court emphasized that it is the trial court’s responsibility to review the DSWD’s recommendation and ensure that the offender has been genuinely rehabilitated.
    What is the role of the trial court in these cases? The trial court must independently assess the DSWD’s recommendation, examining concrete facts to determine if the youthful offender is truly ready to reintegrate into society.
    What legal provision is central to this case? Article 196 of Presidential Decree No. 603 (Child and Youth Welfare Code), which outlines the process for dismissing a case against a rehabilitated youthful offender.
    What was the basis of the Supreme Court’s decision? The Court relied on its previous ruling in People v. Ricky Galit, et al., which clarified the roles of the DSWD and the trial court in these matters.
    What is the practical implication of this ruling? The practical implication is that trial courts have the final say in releasing youthful offenders, ensuring a balance between rehabilitation and public safety.

    In conclusion, People v. Candelario and Legarda reinforces the importance of judicial oversight in the reintegration of youthful offenders. The decision ensures that rehabilitation efforts are properly assessed and that the community’s safety remains a paramount concern. By clarifying the roles of the DSWD and the trial court, the Supreme Court has provided a clear framework for handling these sensitive cases, promoting both justice and the well-being of youthful offenders.

    For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

    Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
    Source: PEOPLE OF THE PHILIPPINES, VS. LUDIGARIO CANDELARIO AND GERRY LEGARDA, G.R. No. 125550, July 11, 2000

  • Adoption Process in the Philippines: Ensuring Child Welfare and Legal Compliance

    The Importance of DSWD Involvement in Philippine Adoption Cases

    A.M. No. RTJ-96-1362, July 18, 1997

    Adoption is a deeply personal and legally intricate process aimed at providing a stable and loving home for children in need. However, when proper procedures are bypassed, the very welfare of the child the law seeks to protect is put in jeopardy. This case highlights the critical role of the Department of Social Welfare and Development (DSWD) in adoption proceedings in the Philippines, emphasizing that adherence to legal protocols is non-negotiable to safeguard the child’s best interests.

    In this case, a judge and a social welfare officer were found to have circumvented the required DSWD involvement in an adoption case. This resulted in an adoption decree that was legally flawed and potentially detrimental to the child’s well-being. The Supreme Court’s decision serves as a stern reminder of the importance of following established procedures and the consequences of failing to do so.

    Legal Framework for Adoption in the Philippines

    The legal framework governing adoption in the Philippines is primarily based on Presidential Decree No. 603, also known as “The Child and Youth Welfare Code.” Article 33 of this decree is particularly crucial, as it mandates the involvement of the DSWD in adoption cases. This article explicitly states:

    “No petition for adoption shall be granted unless the Department of Social Welfare, or the Social Work and Counselling Division, in case of Juvenile and Domestic Relations Courts, has made a case study of the child to be adopted, his natural parents as well as the prospective adopting parents, and has submitted its report and recommendations on the matter to the court hearing such petition. The Department of Social Welfare shall intervene on behalf of the child if it finds, after such case study, that the petition should be denied.”

    To further reinforce this requirement, the Supreme Court issued Circular No. 12, dated October 2, 1986, directing Regional Trial Courts to notify the DSWD of any pending adoption cases and to strictly comply with Article 33. The circular also specifies that court social workers should coordinate with the DSWD in preparing and submitting case studies.

    These legal provisions are designed to ensure that adoptions are conducted responsibly and ethically, with the child’s welfare as the paramount concern. The DSWD’s involvement provides an independent assessment of the suitability of the adoptive parents and the circumstances surrounding the child’s adoption.

    Case Summary: DSWD vs. Judge Belen and Elma P. Vedaña

    The case revolves around the adoption of a minor, Zhedell Bernardo Ibea, by her naturalized American citizen relatives, the spouses Desiderio Soriano and Aurora Bernardo-Soriano. The adoption petition was filed in the Regional Trial Court of Lingayen, Pangasinan, and assigned to Branch 38, presided over by Judge Antonio M. Belen. Social Welfare Officer II Elma P. Vedaña, from the Office of the Clerk of Court, was also involved in the proceedings.

    The DSWD filed an administrative complaint against Judge Belen and Ms. Vedaña, alleging that the adoption decree was issued without proper DSWD involvement. Specifically, the DSWD claimed that it had no record of the adoption case and that Judge Belen never ordered a home and child study report from the DSWD. Furthermore, it was alleged that Ms. Vedaña asked for money from the adopting parents to expedite the process.

    The key events and allegations are summarized below:

    • Spouses Soriano filed a petition to adopt their niece, Zhedell.
    • Judge Belen granted the petition, citing a supposed DSWD report.
    • The DSWD had no record of the case and filed a complaint.
    • It was alleged that Vedaña solicited money from the adoptive parents.

    Judge Belen defended his actions by claiming that he instructed Ms. Vedaña to conduct the necessary studies as part of her duties. Ms. Vedaña, in turn, stated that she was never directed to coordinate with the DSWD and denied soliciting money. However, the Office of the Court Administrator (OCA) found that both respondents had violated Article 33 of Presidential Decree No. 603 and Circular No. 12 of the Supreme Court.

    The Supreme Court emphasized that Judge Belen should have notified the DSWD at the outset of the adoption proceedings and ensured that proper coordination took place. It also noted that Ms. Vedaña had overstepped her role by independently conducting the case study without DSWD involvement.

    As the Court stated: “By respondent’s failure to do so, he may well have wittingly or unwittingly placed in jeopardy the welfare and future of the child whose adoption was under consideration.”

    Ultimately, Judge Belen was censured, and Ms. Vedaña was reprimanded for their respective roles in the procedural lapses. The Court, however, acknowledged that Judge Belen acted in good faith, believing that Ms. Vedaña was coordinating with the DSWD. The allegation of corruption against Ms. Vedaña was also not substantiated.

    Practical Implications of the Ruling

    This case serves as a crucial reminder to judges, social workers, and prospective adoptive parents of the importance of strictly adhering to the legal requirements for adoption in the Philippines. Failure to involve the DSWD in the adoption process can lead to legal complications, delays, and, most importantly, jeopardize the welfare of the child.

    The ruling reinforces the DSWD’s central role in ensuring that adoptions are conducted ethically and in the best interests of the child. It also highlights the need for clear communication and coordination between the courts, social workers, and the DSWD throughout the adoption process.

    Key Lessons

    • Judges must notify the DSWD of all adoption cases at the outset.
    • Social workers must coordinate with the DSWD in conducting case studies.
    • Adoption decrees issued without DSWD involvement may be deemed invalid.
    • Prospective adoptive parents should ensure that all legal requirements are met.
    • Child’s welfare is the paramount consideration in all adoption proceedings.

    Frequently Asked Questions (FAQs)

    Q: What is the role of the DSWD in adoption cases?

    A: The DSWD is responsible for conducting case studies of the child, the natural parents, and the prospective adoptive parents. They submit a report and recommendations to the court to ensure the adoption is in the child’s best interest.

    Q: What happens if the DSWD is not involved in an adoption case?

    A: If the DSWD is not involved, the adoption decree may be considered invalid, and the adoption process may have to be restarted.

    Q: What should I do if I suspect corruption or irregularities in an adoption case?

    A: You should immediately report your concerns to the DSWD, the Office of the Court Administrator, or other relevant authorities.

    Q: What are the qualifications for becoming an adoptive parent in the Philippines?

    A: The qualifications vary but generally include being of legal age, possessing good moral character, being financially stable, and being capable of providing a loving and nurturing environment for the child.

    Q: How long does the adoption process typically take in the Philippines?

    A: The duration of the adoption process can vary depending on the complexity of the case and the workload of the relevant agencies and courts. It can take anywhere from several months to a few years.

    ASG Law specializes in Family Law, including adoption proceedings. Contact us or email hello@asglawpartners.com to schedule a consultation.