Case Digest (G.R. No. 243288)
Facts:
Dr. Ruben C. Bartolome v. Republic of the Philippines, G.R. No. 243288, August 28, 2019, Supreme Court Second Division, Caguioa, J., writing for the Court.
In 2014, petitioner Dr. Ruben C. Bartolome, a resident of Parañaque City, filed a petition under Rule 103 of the Rules of Court before Branch 258, Regional Trial Court (RTC) of Parañaque City (S.P. Proc. Case No. 14-0100), seeking to change the name appearing on his birth certificate from “Feliciano Bartholome” to “Ruben Cruz Bartolome.” After the required posting and publication, petitioner presented several government-issued documents (medical diploma, CSC certificate, PRC ID, marriage contract, passport, senior citizens ID, NBI clearance) bearing the name “Ruben C. Bartolome” to support his claim of habitual use.
The Office of the Solicitor General (OSG) was notified and the Office of the City Prosecutor of Parañaque City was deputized to represent the State, but the State filed no comment or controverting evidence and did not move to dismiss; petitioner’s father and siblings were never impleaded. After trial, the RTC denied the petition on three grounds: failure to exhaust administrative remedies (the court held a change of first name should have been pursued under R.A. 9048), insufficiency of evidence to prove habitual and continuous use of the name “Ruben C. Bartolome” since childhood, and improper venue (the RTC found that a correction of surname belonged to the RTC of Manila under Rule 108).
Petitioner appealed to the Court of Appeals (CA), which affirmed the RTC: the CA held that the matter should have been filed under R.A. 9048, that petitioner failed to prove the family surname was actually spelled “Bartolome,” and thus denied the appeal; the CA subsequently denied petitioner’s ...(Pro-only)
Issues:
- Procedural: Must a petitioner seeking changes or corrections to name entries first file an administrative petition under R.A. 9048 (as amended by R.A. 10172) before invoking judicial remedies under Rule 103 or Rule 108?
- Substantive: Do the specific changes sought here — changing the first name from “Feliciano” to “Ruben,” entering the middle name “Cruz,” and correcting the surname “Bartholome” to “Bartolome” — fall within the administrative remedy of R.A. 9048 (as amended) or must they be pursued under Rule 103 or Rule 108?
- Substantive/factual: Did petitioner present sufficient evidence to justify granting judicial relief under Rule 103 (habitual and continuous use ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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