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 ...

Facts:

1. Petitioner's Background: Anita Po, also known as Veronica Pao, a 16-year-old minor, filed a petition in the Court of First Instance of Baguio and Benguet on August 28, 1968. She sought to change her name from Anita Po to Veronica Pao and correct her birth records.
2. Requested Corrections:
   • Her father's name, recorded as "Po Yu," should be corrected to "Pao Yu."
   • Her mother's name, recorded as "Pakiat Chan," should be corrected to "Helen Chan."
3. Basis for Corrections:
   • The petitioner claimed that her mother's maiden name is Helen Chan, and "Pakiat" is her maternal grandmother's name.
   • She asserted that her father's correct surname is "Pao," not "Po," due to a common misunderstanding of Chinese names.
   • She had been baptized as Veronica Pao and had always been known by that name.
4. Trial Court Proceedings:
   • The Office of the Solicitor General opposed the petition, arguing that the remedies sought (change of name and correction of entries) are governed by separate rules (Rule 103 and Rule 108 of the Rules of Court).
   • The Solicitor General contended that the petition failed to meet the requirements of Rule 108, as the civil registrar and affected parties were not included in the petition.
5. Trial Court Decision:
   • The trial court ruled in favor of the petitioner, allowing the name change and corrections in the civil registry.

Issue:

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Ruling:

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Ratio:

1. Separate Proceedings for Change of Name and Correction of Entries:
   • Rule 103 (change of name) and Rule 108 (correction of entries in the civil registry) are distinct and require separate compliance.
   • The summary procedure under Rule 108 is limited to innocuous or clerical errors, not material changes like altering a surname.
2. Material Changes Require Adversarial Proceedings:
   • The corrections sought by the petitioner involved the identities of her parents, which are material and require a more rigorous process.
3. Indispensable Parties:
   • The local civil registrar and other affected parties must be included in the proceeding for a valid correction of entries.
4. No Justification for Change of Name Without Proof of Error:
   • The petitioner's claim to use the surname "Pao" was based on the assumption that her father's name was erroneously recorded as "Po Yu." However, she provided no proof of this error.
   • Until the alleged error in her father's name is proven, there is no basis for allowing her to change her surname.

Conclusion:

The Supreme Court reversed the trial court's decision, declaring it without force or effect. The entries in the local civil registry of La Trinidad, Benguet, pertaining to Anita Po and her parents, remain unchanged.