G.R. No. 250584 - Calera vs. Hoegh Fleet Services Philippines, Inc.

Petitioner Matron M. Ohoma (also known as Matiorico M. Ohomna) initiated the petition before the Regional Trial Court (RTC) on March 26, 2014, under Special Proceedings Case No. 142-14.
The petition sought the cancellation of his Certificate of Live Birth with Registry Number 45-86 (referred to as the first birth certificate) on the ground that it contained erroneous entries regarding his first and last names.
Petitioner asserted that:

He was born on May 13, 1986, in Aguinaldo, Ifugao.
His birth was later recorded on February 8, 2000, under Certificate of Live Birth with Registry Number 2000-24 (referred to as the second birth certificate), which he claimed contains the correct data.
The first birth certificate, registered on June 13, 1986, contained incorrect entries: his first name was recorded as "Matron" instead of "Matiorico" and his last name as "Ohoma" instead of "Ohomna."
He has been known and has consistently used the names Matiorico Ohomna in both public and private transactions.
Consequently, he argued that the second birth certificate should be retained and the first canceled.

The RTC found the petition to be sufficient both in form and substance upon the filing, as evidenced by its Order on May 14, 2014, which also mandated publication of the Order in a newspaper of general circulation for three consecutive weeks.
The Office of the Provincial Prosecutor of Ifugao (deputized to assist the Office of the Solicitor General) participated in the proceedings, and an order of general default was entered due to the absence of any opposing party.
Petitioner presented the following documents as evidence:

The RTC granted the petitioner’s petition.
The Order directed the Local Civil Registrar of Aguinaldo and the National Statistics Office (now the Philippine Statistics Authority) to cancel the first birth certificate, citing errors that resulted in confusion regarding petitioner’s identity.

The appeal argued that the petitioner’s birth had already been validly registered within the legally prescribed period, hence the second registration should be invalid.
The appeal asserted that any errors in the first birth certificate should have been corrected under Rule 108 of the Rules of Court rather than through cancellation.

The Court of Appeals annulled and set aside the RTC ruling.
It held that petitioner’s birth, having been registered within the required 30-day period (as stipulated by the Office of the Civil Registrar-General Administrative Order No. 1, Series of 1983), precluded the possibility of a valid late registration.
Consequently, the CA ruled that the proper remedial action should have been a petition for correction of entries (under Rule 108) on the first birth certificate, rather than the cancellation of that certificate.

Petitioner moved for reconsideration, which was denied through a Resolution dated May 16, 2018.
The case was elevated to the Supreme Court for review to resolve whether the CA committed reversible error in annulling the RTC decision.

Whether the Court of Appeals committed reversible error in annulling the Regional Trial Court’s ruling that ordered the cancellation of petitioner’s first birth certificate.

The central issue revolved around the validity of petitioner’s second birth certificate given that his birth had already been registered within the legally prescribed 30-day period.
Whether the errors contained in the first birth certificate (regarding petitioner’s first and last names) warrant cancellation or would be more appropriately remedied through a petition for correction under Rule 108.