G.R. No. 132980 - Republic vs. Labrador

The petition involves a request to correct entries in the birth record of Sarah Zita CaAon Erasmo.
The erroneous entries include the child’s name being recorded as “SARAH ZITA CAAON ERASMO” instead of “SARAH ZITA CAAON” and the mother’s name recorded as “ROSEMARIE B. CAAON” instead of “MARIA ROSARIO CAAON.”
The proceedings were initiated under summary action pursuant to Rule 108 of the Revised Rules of Court and Article 412 of the Civil Code.

Respondent Gladys C. Labrador, who is the petitioner’s aunt, filed the petition claiming that the error occurred when she reported the birth details of her niece to the Local Civil Registrar of Cebu City.
It was asserted that the mother’s name was erroneously given as “Rosemarie” because that was the familiar name of Maria Rosario CaAon, who actually resides abroad.
The factual allegation further included that the birth registration error had significant consequences, namely altering the filiation and legitimacy of Sarah Zita.

The petition was filed on September 26, 1997, with subsequent directions by the trial court to set the hearing and to publish a notice in a newspaper of general circulation in Cebu City for three consecutive weeks.
At the hearing on October 29, 1997, evidence was presented which included testimony from Respondent Labrador, documentary evidence (such as Maria Rosario’s birth certificate), and a certification from the civil registrar that there was no record of marriage between Maria Rosario and Degoberto Erasmo.
The trial court eventually ruled in Respondent Labrador’s favor by ordering the necessary corrections in the civil registry.

The Regional Trial Court of Cebu City, in its decision, granted the petition by ordering the Local Civil Registrar to correct the entries in both the child’s and the mother’s names in the birth certificate.
The decision was intended to rectify what the trial court considered “erroneous” entries in order to reflect accurate information.

Disagreeing with the trial court’s disposition, the Solicitor General directly brought the petition to the Supreme Court on a pure question of law, challenging the applicability of the summary proceeding for substantive alterations.

Whether a summary proceeding under Rule 108 may be used to correct errors in a civil registry that affect a person’s civil status, such as changing the filiation of a child from legitimate to illegitimate.
Whether Rule 108 of the Revised Rules of Court, in conjunction with Article 412 of the Civil Code, may be applied to impugn, modify, or alter substantive rights and entries in the record of birth.
Whether the correction of such errors, which are substantial in nature and affect the rights of third parties (including the child, her parents, and potentially creditors), may be granted without full and adversarial proceedings.