Case Digest (G.R. No. 203371) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines vs. Charlie Mintas Felix (G.R. No. 203371, June 30, 2020), respondent Charlie Mintas Felix, also known as Shirley Mintas Felix, alleged that he was born on October 1, 1976 in Itogon, Benguet, but his first birth certificate, registered with the Local Civil Registrar (LCR) of Itogon, erroneously recorded his first name as “Shirley,” his gender as “female,” and his father’s surname as “Filex.” Respondent possessed a second birth certificate, filed with the LCR of Carrangalan, Nueva Ecija, which correctly identified him as “Charlie,” “male,” and “Felix.” When he requested an authenticated copy from the National Statistics Office (NSO), he received only the erroneous Itogon record. On July 30, 2007 he filed a petition under Rule 108 of the Rules of Court before the Regional Trial Court (RTC) of La Trinidad, Benguet, seeking correction of the Itogon entries and cancellation of the Nueva Ecija certificate. The Republic of the Philippines, through the Off Case Digest (G.R. No. 203371) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Nature of Petition
- Petitioner Republic of the Philippines (through the Office of the Solicitor General) challenged the Court of Appeals’ affirmance of the trial court’s grant of respondent’s petition for correction and cancellation of birth certificates.
- Respondent Charlie Mintas a.k.a. Shirley Mintas Felix is the subject of two birth registrations.
- Birth Registrations and Petition
- First birth certificate (LCR-Itogon, Benguet) erroneously showed:
- First name “Shirley” instead of “Charlie”
- Gender “female” instead of “male”
- Father’s surname “Filex” instead of “Felix”
- Second birth certificate (LCR-Carrangalan, Nueva Ecija) bore the correct entries.
- On July 30, 2007, respondent petitioned RTC-La Trinidad, Benguet under Rule 108 to:
- Correct the entries in the Itogon certificate
- Cancel the Carrangalan certificate
- The Republic moved to dismiss for lack of jurisdiction over LCR-Carrangalan.
- Trial Court and Court of Appeals Decisions
- RTC Decision (July 23, 2009) granted correction and cancellation.
- CA Decision (April 23, 2012) affirmed, holding cancellation incidental to the correction petition and joinder proper.
- CA Resolution (August 30, 2012) denied the Republic’s motion for reconsideration.
- Supreme Court Proceedings
- The Republic filed a Rule 45 petition, reasserting lack of jurisdiction and invoking RA 9048/10172 to divest RTCs of correction powers.
- Respondent maintained that joinder was required by the rule against multiplicity of suits.
Issues:
- Ancillary Jurisdiction
- Did RTC-La Trinidad, Benguet have jurisdiction to order LCR-Carrangalan, Nueva Ecija to cancel respondent’s second birth certificate as incidental to the correction petition?
- Statutory Jurisdiction under RA 9048/10172
- Did RA 9048, as amended by RA 10172, divest regional trial courts of jurisdiction over petitions for correction of civil registry entries?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)