Case Digest (G.R. No. 203371)
Facts:
Republic of the Philippines v. Charlie Mintas Felix, G.R. No. 203371, June 30, 2020, First Division, Lazaro‑Javier, J., writing for the Court.Respondent Charlie Mintas a.k.a. Shirley Mintas Felix filed a Petition for Correction of Entries on July 30, 2007, alleging that his birth registered with the Local Civil Registrar (LCR) of Itogon, Benguet contained erroneous entries: first name recorded as “Shirley” instead of “Charlie,” sex recorded as “female” instead of “male,” and his father’s surname spelled “Filex” instead of “Felix.” He possessed a second birth certificate on file with the LCR‑Carrangalan, Nueva Ecija that contained the correct entries; however, when he requested an authenticated copy from the National Statistics Office (NSO), the NSO released the erroneous Itogon certificate.
The petition asked the Regional Trial Court (RTC), La Trinidad, Benguet to correct the entries in the Itogon record and to cancel the Carrangalan registration. The Office of the Solicitor General (OSG) for the Republic of the Philippines moved to dismiss or limited relief on the ground that the RTC‑La Trinidad lacked jurisdiction to order the LCR‑Carrangalan (Nueva Ecija) to cancel a registration outside its territorial locus. The RTC conducted publication, received documentary and testimonial evidence (including medical certificate and scrotal ultrasound), and by Decision dated July 23, 2009 granted the petition: it ordered correction of the Itogon entries and directed the LCR‑Carrangalan to cancel the second birth registration.
The Republic appealed to the Court of Appeals (CA). By Decision dated April 23, 2012, the CA (Baltazar‑Padilla, J.) affirmed the RTC, holding the cancellation of the Carrangalan registration incidental to and a necessary consequence of the correction of the Itogon entry and that joining the two remedies avoided multiplicity of suits; the Republic’s motion for reconsideration was denied by CA Resolution dated August 30, 2012. The Republic filed a petition under Rule 45 for review on certiorari before the Supreme Court, challenging (1) the RTC’s...(Pro-only)
Issues:
- Did the Court of Appeals commit reversible error in upholding the trial court’s jurisdiction to order the cancellation of the LCR‑Carrangalan, Nueva Ecija registration as incidental to the RTC‑La Trinidad’s correction of the Itogon entry?
- Do R.A. No. 9048, as amended by R.A. No. 10172, divest the Regional Trial Courts of jurisdiction over petitions for correction of entries in the civ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)