G.R. No. 250199 - Republic vs. Boquiren

Oliver M. Boquiren and Roselyn M. Boquiren were born out of wedlock on October 8, 1997, and November 20, 1999, respectively, to parents Oscar D. Boquiren and Rosalinda B. Macaraeg.
Their births were belatedly registered with the Local Civil Registry (LCR) of Malasiqui, Pangasinan on April 16, 2002.
Oscar and Rosalinda married on April 18, 2002, after the births of Oliver and Roselyn.

Based on the Affidavits of Legitimation executed by the parents, the LCR annotated respondents’ Certificates of Live Birth (COLBs) on May 20, 2002, with the note: “LATE REGISTRATION, LEGITIMATED BY SUBSEQUENT MARRIAGE OF PARENTS on 4-18-2002 at Mal. Pang.”
Respondents began using the surname “Boquiren” in school and official records following this annotation.

In 2015, while securing copies of COLBs, Rosalinda was informed by the Philippine Statistics Authority (PSA) that Oscar’s prior marriage to Gloria Erese Pangilinan on January 29, 1987, made the legitimation ineffective.
Consequently, on May 4, 2016, respondents filed a petition with the Regional Trial Court (RTC) seeking correction of entries in their birth certificates.
They sought to cancel the annotation of legitimation on their COLBs and wished the LCR to instead annotate the Affidavits of Acknowledgment executed by Oscar dated March 28, 2016, so they could continue using the surname “Boquiren.”

The RTC granted respondents’ petition on November 4, 2016, ordering cancellation of the Affidavit of Legitimation annotations and registration of the Affidavit of Acknowledgment.
The RTC reasoned that the marriage of respondents’ parents was void due to bigamy, invalidating legitimation under Republic Act No. 9255.
The petitioner (Republic of the Philippines through the Office of the Solicitor General) moved for reconsideration, which was denied.
The petitioner appealed to the Court of Appeals, which affirmed the RTC decision on March 29, 2019, and denied the motion for reconsideration on October 8, 2019.
The CA held that the correction involved substantial amendments, requiring an adversarial proceeding under Rule 108, which were duly observed.
The CA found Oscar’s prior marriage valid and thus ruled the subsequent marriage to Rosalinda void and the legitimation ineffective.
It rejected petitioner’s claim that the RTC lacked jurisdiction to rule on marriage validity in a Rule 108 proceeding, citing precedents allowing collateral inquiry of marriage validity when essential to the case.
The CA also ruled respondents were proper parties to question their status and that legitimacy can be questioned if paternity is not denied.

Petitioner contended the RTC and CA erred in ruling on the validity of marriage and legitimacy through Rule 108 proceedings, which are improper forums for such declarations.
Petitioner argued that respondents are not proper parties to impugn their own legitimation status.

The petitioner filed a Petition for Review on Certiorari before the Supreme Court pursuant to Rule 45.
The Supreme Court granted the petition and reversed and set aside the RTC and CA decisions, dismissing the correction petition.
The Court directed the LCR to annotate the PSA certification of Oscar’s prior marriage on respondents’ COLBs.

Whether or not the Regional Trial Court had jurisdiction under Rule 108 to determine the validity of the marriage of respondents’ parents and consequently invalidate the legitimation of respondents.
Whether respondents are the proper parties to impugn their own legitimated status and correct the entries in their birth certificates through a Rule 108 petition.
Whether the correction or cancellation of entries in the civil registry can include nullification of a marriage and challenge to legitimacy in a collateral proceeding.