Case Digest (G.R. No. 241369)
Facts:
The case involves Sasha M. Cabrera (petitioner) against the Philippine Statistics Authority (formerly the National Statistics Office), the Office of the Consul General at the Philippine Embassy in Kuala Lumpur, and the Office of the Solicitor General (respondents). The events leading to this case began with the petitioner’s birth on July 20, 1989, at Zuba Estate, Lahad Datu, Sabah, Malaysia. Due to the considerable distance from their residence to the Philippine Embassy in Kuala Lumpur, her mother reported her birth only on August 27, 2008. The National Statistics Office recorded this birth on January 29, 2009, under Registry Number 2009-4580024. However, an error occurred, and the date of birth was incorrectly recorded as July 20, 1980. Instead of correcting this error, the petitioner’s mother registered her birth a second time, leading to a second Report of Birth recorded in March 2010 under Registry Number 2010-4580208. This duplication caused the petitioner difficulties i...
Case Digest (G.R. No. 241369)
Facts:
Background of the Case
Petitioner Sasha M. Cabrera was born on July 20, 1989, in Zuba Estate, Lahad Datu Sabah, Malaysia. Due to the distance between her residence and the Philippine Embassy in Kuala Lumpur, her mother reported her birth on August 27, 2008. The National Statistics Office (now the Philippine Statistics Authority or PSA) received and recorded her first Report of Birth on January 29, 2009, under Registry Number 2009-4580024.
Error in Birth Registration
Petitioner later discovered that her year of birth was incorrectly recorded as 1980 instead of 1989. Instead of correcting the error with the Philippine Embassy, her mother registered her birth a second time in March 2010, under Registry Number 2010-4580208.
Legal Proceedings
Having two Reports of Birth caused petitioner difficulties in securing official documents. She filed a petition before the Regional Trial Court (RTC) of Davao City, Branch 17 (RTC-Br. 17), to cancel her first Report of Birth. The RTC-Br. 17 granted her petition on November 19, 2012, ordering the cancellation of the first Report of Birth. The Office of the Solicitor General (OSG) appealed to the Court of Appeals (CA), which reversed the RTC decision, ruling that the proper remedy was to file a petition for correction of entry under Rule 108 of the Rules of Court.
Re-filing of the Petition
Instead of filing a motion for reconsideration, petitioner re-filed her petition before the RTC of Davao City, Branch 14 (RTC-Br. 14), seeking to correct her year of birth and cancel her second Report of Birth. The RTC-Br. 14 dismissed the petition motu proprio, citing improper venue, as the petition should have been filed in Quezon City, where the PSA is located.
Issue:
The sole issue before the Court is whether the RTC-Br. 14 erred in dismissing the re-filed petition on the ground of improper venue.
Ruling:
The Supreme Court ruled in favor of the petitioner, holding that the RTC-Br. 14 erred in dismissing the petition motu proprio on the ground of improper venue. Venue is procedural, not jurisdictional, and can be waived if not objected to at the earliest opportunity. Since the OSG did not object to the venue in Davao City, the RTC-Br. 14 should have proceeded with the case. The Court reinstated the petition and remanded it to the RTC-Br. 14 for further proceedings.
Ratio:
Venue is Procedural, Not Jurisdictional: Venue pertains to the place of trial and is a matter of procedural law. It can be waived if not raised in a motion to dismiss or in the answer. Courts cannot motu proprio dismiss a case on the ground of improper venue unless the parties object.
Convenience of the Parties: The rules on venue are designed for the convenience of the parties and their witnesses. Since petitioner resides in Davao City and the PSA has a field office there, Davao City is the most convenient venue.
Waiver of Venue: The OSG did not object to the venue in Davao City during the proceedings before the RTC-Br. 17. Thus, the objection to venue was deemed waived, and the RTC-Br. 14 should not have dismissed the case motu proprio.
Promotion of Justice: The RTC-Br. 14’s dismissal of the petition defeated the ends of justice. The Court emphasized that procedural rules should be used to promote, not hinder, the resolution of cases on their merits.
Conclusion:
The Supreme Court granted the petition, reversed the RTC-Br. 14’s orders, and reinstated the case for further proceedings. The Court reiterated that venue is a procedural matter that can be waived and should not be used to dismiss cases motu proprio without proper objection from the parties.