G.R. No. 68635 - IN RE: Laureta

The petitioner-appellant, Sincio C. Yu, sought to have his name corrected in the Local Civil Registry of the City of Manila.
His name was erroneously recorded as “SINCIO C. YEE” instead of the correct “SENCIO YU.”

The petitioner alleged that he was born on May 16, 1967, in Manila, to Chinese citizens Yu Cho Koo and Tiu Oh Yek.
He was registered in the Bureau of Immigration under the name “Sincio C. Yu,” consistent with his father’s surname, “Yu.”
The birth entry in the Office of the Local Civil Registrar for the City of Manila (Registry No. 1543) erroneously recorded his name as “Sincio Yee.”
The mistake allegedly originated from the report of a Chinese midwife who attended the delivery, where she wrote his name as “Sincio” (instead of “Sencio”) and misspelled his surname as “Yee” (instead of “Yu”).
Documentary support included a certified true copy of the petitioner’s birth certificate and affidavits from both his father and the midwife.

In Civil Case No. 46525 before the Court of First Instance of Manila, the petition to correct the name was denied.
The denial was based on the view that the requested correction was substantial and fell outside the scope of mere clerical error as defined under Article 412 of the Civil Code.

The opposing party (the Republic of the Philippines) argued that the desired amendment was not merely a clerical error but amounted to a substantive change in the petitioner’s name.
This opposition was rooted in the interpretation that the transformation from “Sincio” to “Sencio” entailed more than a harmless correction.
During the hearings, the Solicitor representing the government withdrew the objection regarding the surname change (from “Yee” to “Yu”), as the petitioner’s original record confirmed “Yu” was indeed his correct surname.

Whether the alteration of the petitioner’s first name from “Sincio” to “Sencio” constitutes a mere clerical error.
Or, alternatively, whether such a change is substantial enough to be characterized as a change of name, thus requiring a separate petition.

Determining if the correction falls within the ambit of Article 412 of the Civil Code, which deals with the rectification of clerical errors.
Assessing whether the evidence provided (affidavits, birth certificate, and other documentary materials) is sufficient to validate the correction.

The implications of correcting the error on the petitioner’s record in the Office of the Local Civil Registrar.
The subsequent harmonization of the petitioner’s personal documents (including the visa and other public records) with the corrected name.