G.R. No. 119930 - Insular Life Assurance Co., Ltd. vs. National Labor Relations Commission

On October 15, 1935, Matea Piconada, who was single at the time, delivered a baby girl at the Maternity and Children's Hospital, City of Manila.
Upon the delivery, Matea Piconada informed the hospital authorities that the child’s name was Henrietta Piconada and that her father was unknown.

The hospital complied with the information provided by Matea Piconada by reporting the details to the local civil registrar.
The official record established in the civil register and the corresponding birth certificate (designated as Exhibit A in the records) recorded the child's name as Henrietta Piconada and indicated that her father was unknown.

Almost twenty years later, on June 6, 1955, William H. Brown instituted an action in the Court of First Instance of Manila.
In his petition, William H. Brown asserted that:

Henrietta Piconada is his natural daughter.
Since the commencement of her schooling, she had been registered and known as Henrietta Brown.
From early childhood, she had been under his custody for education and support—with the knowledge and consent of her mother.

His prayer was for the Civil Registrar of the City of Manila to issue an order directing the rectification of the birth certificate by:

The petition reiterated that the changes were intended to bring the record in conformity with Article 412 of the New Civil Code.

An opposition was filed by the Solicitor General on behalf of the Government.
After appropriate proceedings, the Court of First Instance of Manila issued a decision granting the petition except for the correction regarding Henrietta’s nationality.
The disposition ordered that the Civil Registrar of Manila should:

The Government appealed the decision, primarily relying on the case of Ty Kong Tin vs. Republic of the Philippines.
The appeal emphasized that Article 412 of the Civil Code permits only the correction of clerical errors in civil registers, not alterations that affect substantive matters such as the civil status or nationality of the persons involved.
The argument stressed that a retrospective change in entries would be tantamount to endorsing an irregular method of acknowledging a minor as a natural child without following the necessary judicial procedures as required by law (under Article 281 of the Civil Code).

Whether the petitioner's request to amend the birth certificate by adding his surname and inserting his personal details qualifies as a mere correction of clerical errors under Article 412 of the Civil Code.

Is altering the record to include a change in the child's name a clerical correction, or does it affect the substantive fact of paternity?
Does an addition of the father's details, which were absent when the record was originally made, fall within the ambit of Article 412?

Whether the petitioner's further request to change the child’s recorded nationality from “Filipino” to “American” constitutes a substantial alteration that goes beyond correcting a clerical error.

Does this change imply a recognition of a different civil or national status that would require a full judicial process rather than a summary correction?
Would this retrospective amendment to official records contravene the mandatory requirement of judicial approval for changing facts initially recorded by the local civil registrar?

Whether the retrospective correction of the official entries, as requested by the petitioner, improperly alters established legal facts recorded at the time of the event.