Case Digest (G.R. No. L-27159)
Facts:
- The case "In re: Chan v. Local Civil Registrar of Manila," G.R. No. L-27159, was decided by the Supreme Court of the Philippines on September 17, 1969.
- Petitioner Chan Chin sought to amend the birth records of his four children: Teresita Chan, Alicia Chan, Virginia Chan, and Vicente Chan.
- Teresita's birth record listed her surname as "Uy," with her father as "Chi Uy" and mother as "Juanita Go," and birthplace as "Amoy, Chinkang."
- Chan Chin requested changes to reflect her name as "Teresita Chan," her father's name as "Chan Chin," her mother's name as "Juanita Co," and her birthplace as "Manila."
- Alicia's record showed her name as "Alicia Ching," with parents listed as "Chang Ching" and "Juanita Go," and Chan sought to change her name to "Alicia Chan," among other modifications.
- Virginia's record was correctly listed as "Virginia Chan," with her father as "Chin Chan."
- Vicente's name was recorded as "Vicente Chan," with his father as "Chan Ching."
- The lower court initially granted Chan Chin's petition, considering the requested corrections substantial.
- The Local Civil Registrar of Manila contested this ruling, leading to an appeal.
Issue:
- (Unlock)
Ruling:
- The Supreme Court reversed the order of the Court of First Instance of Manila, which had granted Chan Chin's petition for the correction of the birth records.
- The Court ruled that the changes sought were substantial and could not be corrected in a summary proceeding as provided under Article 412 of the Civil Code.
- The Court found that the fail...(Unlock)
Ratio:
- The Court's ruling was based on the interpretation of Article 412 of the Civil Code, which requires a judicial order for corrections to civil registry entries.
- Substantial changes affecting a person's identity or status can...continue reading
Case Digest (G.R. No. L-27159)
Facts:
In the case "In re: Chan v. Local Civil Registrar of Manila," G.R. No. L-27159, the Supreme Court of the Philippines rendered its decision on September 17, 1969. The petitioner-appellee, Chan Chin, sought to amend the birth records of his four children: Teresita Chan, Alicia Chan, Virginia Chan, and Vicente Chan. The birth record of Teresita indicated her family name as "Uy," with her father listed as "Chi Uy" and her mother as "Juanita Go," while her birthplace was noted as "Amoy, Chinkang." Chan Chin requested changes to reflect her name as "Teresita Chan," her father's name as "Chan Chin," her mother's name as "Juanita Co," and her birthplace as "Manila." Similarly, Alicia's record showed her name as "Alicia Ching," with parents listed as "Chang Ching" and "Juanita Go," and Chan sought to change her name to "Alicia Chan," among other modifications. Virginia's record was correctly listed as "Virginia Chan," with her father as "Chin Chan," while Vicente's name was recorded as "Vicente Chan," with his father as "Chan Ching." The lower court initially granted Chan Chin's petition, deeming the requested corrections as substantial. However, the Local Civil Registrar of Manila, the respondent...