G.R. No. 225899 - Esteva vs. Wilhelmsen Smith Bell Manning, Inc.

On December 11, 2003, Jennifer B. Cagandahan filed a Petition for Correction of Entries in her birth certificate before the RTC of Siniloan, Laguna, alleging she was born January 13, 1981 and registered as female.
She claimed a diagnosis of Congenital Adrenal Hyperplasia (CAH), resulting in both male and female characteristics, with clitoral hypertrophy, underdeveloped ovaries and lack of breast and menstrual development by age 13, and asserted she identifies and functions as male.

The petition was published for three successive weeks and served upon the Solicitor General’s office; the Local Civil Registrar was furnished copies but not impleaded.
Respondent presented medical testimony and a certificate from Dr. Michael Sionzon (UP–PGH Psychiatry) confirming permanent CAH, excess androgen production, ambiguous genitalia, absence of menstruation, and recommending gender change.

In its January 12, 2005 Decision, the RTC granted the petition, ordering the birth certificate amended: name changed from “Jennifer” to “Jeff” and gender from “female” to “male.”
The RTC further directed correction of school records, voter registry, baptismal certificate, and other pertinent documents to conform with the amended entries.

Whether the petition complied with the residency requirement under Rule 103, Sec. 2(b).
Whether the petition improperly failed to implead the Local Civil Registrar as an indispensable party under Rule 108, Sec. 3.

Whether correction under Rule 108 may include change of “sex” or “gender” in a birth certificate.
Whether respondent’s medical condition (CAH) legally qualifies her as “male” for purposes of civil registry entry.