Case Digest (G.R. No. 208005) Core Legal Reasoning Model
Facts:
This case, titled "Re: Adoption of Karen Herico Licerio," revolves around petitioners Joel H. Borromeo and Carmen H. Licerio, who are a married couple with two legitimate children. On May 26, 2005, they filed a verified petition for the adoption of Karen Herico Licerio, Carmen's minor illegitimate daughter, at the Regional Trial Court (RTC) of Marikina City. The RTC granted this petition on June 27, 2006, declaring Karen as the legitimate child of the couple, thus allowing her to inherit and adopting her into their family officially. The court mandated the submission of related adoption documents to the City Civil Registrar of Marikina City and instructed the corresponding rectifications to be made in Karen’s birth certificate.
In July 2006, when petitioners attempted to enforce the adoption ruling at the Office of the Civil Registrar (OCR) of Quezon City, they encountered complications as Karen's birth was also registered at the OCR of Caloocan City. To addre
... Case Digest (G.R. No. 208005) Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners Joel H. Borromeo and Carmen H. Licerio, husband and wife with two legitimate minor children, sought to adopt Karen, the minor illegitimate daughter of Carmen.
- The petition for adoption was filed before the Regional Trial Court (RTC) of Marikina City on May 26, 2005.
- RTC Decision Granting Adoption
- On June 27, 2006, the RTC of Marikina City ruled that the joint adoption of Karen was in her best interest and granted the petition.
- The decision declared Karen Herico Licerio as the legitimate daughter of the petitioners, renamed her Karen Licerio Borromeo, and ordered the petitioners to submit a certified true copy of the adoption decree and a certificate of finality to the City Civil Registrar of Marikina City within 30 days.
- It further instructed the City Civil Registrar of Quezon City to:
- Rectify and annotate the original certificate of birth,
- Issue a new certificate of birth without notations of amendment,
- Seal the original certificate in the civil registry, and
- Submit proof of compliance within 30 days.
- Registration Conflict in the Civil Registry
- On July 12, 2006, petitioners discovered that Karen’s birth was registered in both Quezon City and Caloocan City.
- They were advised that for the proper execution of the June 27, 2006 Decision, the registration in the OCR of Caloocan City had to be cancelled.
- RTC of Caloocan City’s Ruling on Birth Certificate
- On May 23, 2012, the RTC of Caloocan City issued an Order directing the correction of entries in Karen’s Certificate of Live Birth.
- The Order mandated:
- The correction of Karen’s name (dropping the surname “Torres”), and
- The correction of the entry stating the marital status of her parents to “not married”.
- Notably, the RTC did not cancel Karen’s birth registration at the OCR of Caloocan City.
- Motion to Correct the RTC Adoption Decision
- Petitioners filed a Motion to Correct on February 19, 2013, seeking to substitute “City Civil Registrar of Quezon City” with “City Civil Registrar of Caloocan City” in the June 27, 2006 Decision.
- On May 23, 2013, the RTC of Marikina City denied the Motion to Correct, ruling that the June 27, 2006 Decision had become final and executory, rendering it immutable.
- A subsequent Motion for Reconsideration was also denied on July 1, 2013.
- Filing of the Petition for Review on Certiorari
- Despite the aforementioned rulings, petitioners filed a petition for review on certiorari on August 1, 2013.
- The petitioners contended that:
- Adoption and correction of entries in the civil registry are classified as special proceedings,
- Section 6, Rule 39 of the Rules of Court does not apply to such proceedings, and
- A final judgment may be modified to harmonize with justice and the facts.
- The Office of the Solicitor General, in its Comment, agreed with the special nature of the proceedings but suggested that a separate suit may be better suited to resolve the issue of the registration conflict.
Issues:
- Whether the RTC of Marikina City erred in dismissing petitioners’ Motion to Correct the June 27, 2006 Decision on the ground of the finality and immutability of judgment.
- Whether the doctrine of immutability of judgment should yield to an exception when new facts—specifically, the duplicitous registration of Karen’s birth—render the execution of the decision unjust and impossible.
- Whether the proper Office of the Civil Registrar (OCR) to enforce the June 27, 2006 Decision should be re-determined in light of the conflicting registrations in Quezon City and Caloocan City.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)