Facts:

The case involves Saturnina Vda. de Castro as the petitioner-appellee and the Republic of the Philippines as the oppositor-appellant. The case was decided by the First Division of the Supreme Court of the Philippines on January 17, 1985, stemming from a direct appeal on points of law from a decision of the Court of First Instance of Manila in Civil Case No. 70128. The petitioner filed a petition seeking to correct the name of her son, Ramon V. Castro, which was recorded incorrectly in the Civil Registry of Manila. Ramon was born on August 31, 1946, at St. Luke's Hospital. The confusion arose from the fact that three names were proposed for him at birth: Ramon V. Castro, Ramon George Castro, Jr., and George F. Castro. The name "George F. Castro" was erroneously recorded in the civil registry. In her petition, Saturnina asserted that Ramon V. Castro was the true and lawful name of her son, which he had used in all transactions and official documents throughout his...

Facts:

Background of the Case

• Petitioner Saturnina V. Vda. de Castro filed a petition in the Court of First Instance of Manila, seeking to correct the name of her son, Ramon V. Castro, in the Civil Registry of Manila.
• The petitioner alleged that her son was born on August 31, 1946, at St. Luke's Hospital and was known by three names: Ramon V. Castro, Ramon George Castro, Jr., and George F. Castro.
• The name "George F. Castro" was erroneously recorded in the Civil Registry of Manila, while "Ramon V. Castro" was the name consistently used by her son in all private and official transactions since childhood.

Petition and Opposition

• The petitioner requested the court to declare that Ramon V. Castro, George F. Castro, and Ramon George Castro, Jr., are one and the same person and to order the Civil Registrar of Manila to correct the name in the records from "George F. Castro" to "Ramon V. Castro."
• The Republic of the Philippines, through the Solicitor General, opposed the petition, arguing that Article 412 of the Civil Code only allows corrections of clerical errors, not substantial changes affecting civil status or identity.

Lower Court Decision

• The Court of First Instance of Manila granted the petition, ruling that the correction was justified and ordering the Civil Registrar to change the name in the records.

Issue:

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Ruling:

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Ratio:

1. Clerical vs. Substantial Errors: Article 412 of the Civil Code only allows corrections of clerical errors, such as misspellings or obvious mistakes visible to the eyes. Substantial changes, such as those affecting identity, civil status, or citizenship, require a proper adversarial proceeding under Rule 108 of the Revised Rules of Court.
2. Proper Remedy for Change of Name: The Supreme Court emphasized that the correction sought by the petitioner was not a mere clerical error but a substantial change. Therefore, the proper procedure is a petition for change of name under Rule 103, where all interested parties are notified and given the opportunity to be heard.
3. Consistent Jurisprudence: The Court reiterated its consistent ruling in cases like Ty Kong Tin vs. Republic and Lui Lin vs. Republic, which held that substantial alterations in civil registry records cannot be made through summary proceedings under Article 412.

Conclusion:

• The Supreme Court reversed the lower court's decision, holding that the correction sought was not a clerical error and required a proper adversarial proceeding. Costs were imposed against the petitioner-appellee.