Case Digest (G.R. No. L-32600)
Facts:
- The case involves the Republic of the Philippines as the petitioner against Hon. Feliciano Belmonte, Judge of the Court of First Instance of Baguio and Benguet, and private respondent Anita Po (also known as Veronica Pao).
- Anita Po, a 16-year-old minor residing in Baguio City, filed a petition on August 28, 1968, to change her name to Veronica Pao and to correct her birth records.
- She sought to amend her father's name from "Po Yu" to "Pao Yu" and her mother's name from "Pakiat Chan" to "Helen Chan," claiming these errors were due to misunderstandings of Chinese names.
- Anita stated she had been baptized as Veronica Pao and was known by that name.
- The case was filed as Special Proceeding Case No. 642.
- During the hearing on March 4, 1969, the Office of the Solicitor General opposed the petition, arguing that name changes and corrections should not be combined in one proceeding.
- On July 24, 1969, the trial court ruled in favor of Anita, allowing the name change and corrections.
- The Office of the Solicitor General appealed the decision to the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the petitioner, the Republic of the Philippines, and set aside the decision of the Court of First Instance of Baguio and Benguet.
- The Court declared that the entries in ...(Unlock)
Ratio:
- The Supreme Court found that Anita Po's petition was insufficient in both form and substance.
- The Court emphasized that name changes and corrections in the civil registry are governed by separate rules (Rule 103 for name changes and Rule 108 for corrections) and cannot be combined in one proceeding.
- The corrections sought involved significant changes to her parents' identities, necessitating a more adversarial process than what Rule 1...continue reading
Case Digest (G.R. No. L-32600)
Facts:
The case involves the Republic of the Philippines as the petitioner against Hon. Feliciano Belmonte, Judge of the Court of First Instance of Baguio and Benguet, and private respondent Anita Po, also known as Veronica Pao, who was assisted by her mother, Helen Pao. The events leading to this case began on August 28, 1968, when Anita Po, a resident of Baguio City and a 16-year-old minor at the time, filed a petition in the Court of First Instance of Baguio and Benguet. She sought to change her name from Anita Po to Veronica Pao and requested corrections to her birth records. Specifically, she wanted her father's name corrected from "Po Yu" to "Pao Yu" and her mother's name from "Pakiat Chan" to "Helen Chan." Anita claimed that the errors in her birth certificate were due to common misunderstandings of Chinese names. She stated that she had been baptized as Veronica Pao and had always been known by that name. The case was filed as Special Proceeding Case No. 642. During the hearing on March 4, 1969, the Office of the Solicitor General opposed the petition, arguing that the requests for a name change and corrections could not be combined in one proceeding, as they were governed by different rules (Rule 103 for name changes and Rule 108 for corrections in the civil registry). The trial court, presided ove...