A.M. No. RTJ-18-2537 - Bogabong vs. Balindong

The petitioner, Police Senior Superintendent Dimapinto Macawadib, filed a petition for review on certiorari under Rule 45 seeking to nullify and set aside the decisions rendered by the lower courts.
The original decision was rendered by the Regional Trial Court (RTC) of Marawi City, Branch 8, on December 4, 2001, in Special Proceedings No. 782-01, wherein the petitioner’s application for correction of his birth date in his public service records was granted.
On December 17, 2008, the Court of Appeals (CA) nullified the RTC decision and issued a permanent injunction barring petitioner from extending his service past the mandatory retirement age of 56.
A subsequent Motion for Reconsideration was filed by the petitioner, which the CA denied in its Resolution dated February 25, 2009.

According to the records maintained by the Philippine National Police (PNP), the petitioner was born on January 11, 1946, making him subject to compulsory retirement on January 11, 2002 (as provided under Section 39 of Republic Act 6975).
The petitioner, however, filed for late registration of his birth on September 3, 2001, swearing under oath that his true birth date was January 11, 1956.
This discrepancy led the petitioner to file a petition for correction of entry with the RTC of Marawi City, using documentary evidence including a belatedly registered live birth certificate and affidavits.
The RTC, relying on the presented evidence, ordered corrections in the service records of the petitioner at various government agencies (PNP, National Police Commission, Civil Service Commission).

The petitioner’s petition sought not only to correct his birth date but also to affect the integrity of public records held by the PNP, NAPOLCOM, and CSC.
These agencies were not joined as parties in the original proceedings, raising questions as to whether their absence rendered the decision defective.

The timeliness and credibility of the petitioner’s evidence were questioned given that the late registration occurred 45 years after his alleged birth and shortly before his compulsory retirement.
Documentary evidence from other sources such as his marriage certificate, school records, and service records contrasted his claim and supported the 1946 birth date.
The petitioner’s supporting affidavits were challenged on the grounds that they did not demonstrate sufficient disinterest or undergo rigorous testing through cross-examination.

Whether the PNP, together with the National Police Commission (NAPOLCOM) and the Civil Service Commission (CSC), were indispensable parties whose absence rendered the RTC’s decision and subsequent CA actions void.
Whether the RTC had jurisdiction over the petitioner’s case given that the agencies with an interest in the correction of public records were not joined.

Whether the RTC’s decision, having been declared void due to the absence of the indispensable parties, could ever attain finality and be subject to execution.
The implications of applying procedural rules concerning joinder of parties in ensuring a complete adjudication.

Whether the petitioner’s late registration of his birth and the evidentiary submissions (affidavits, birth certificate) were sufficient to establish the true and correct birth date.
The credibility and reliability of the petitioner’s evidence in the light of contradictory documentary evidence from other official records.