Case Digest (G.R. No. 233068) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 2016, Merly Maligaya, also known as Merly M. Maligaya-Sarmiento, filed a petition before the Regional Trial Court (RTC) in Special Proceedings No. NC-2016-2599 to correct entries in her birth certificate. She sought to change her first name from "Merle" to "Merly" and to correct her date of birth from February 15, 1959, to November 26, 1958. Merly supported her petition with documentary evidence including her SSS Member’s Data E-4 Form, voter registration records, voter certification, voter ID, police clearance, and NBI clearance. The RTC found the petition sufficient in form and substance and ordered its publication. After hearing, the RTC granted the correction of both the first name and date of birth. The Office of the Solicitor General (OSG) filed a motion for reconsideration which the RTC denied. The OSG then elevated the case to the Supreme Court through a petition for review on certiorari, arguing that the RTC lacked jurisdiction to order the correction of Merly’s firs Case Digest (G.R. No. 233068) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Filing of Petition
- In 2016, Merly M. Maligaya (also known as Merly M. Maligaya-Sarmiento) filed a petition before the Regional Trial Court (RTC) for correction of entries in her birth certificate.
- The petition sought correction of:
- Her first name from "Merle" to "Merly."
- Her date of birth from February 15, 1959 to November 26, 1958.
- The petition was filed under Rule 108 of the Rules of Court, docketed as Special Proceedings No. NC-2016-2599.
- Merly presented documentary evidence including SSS Member’s Data E-4 Form, Voter’s Registration Record and Certification, Voter’s Identification Card, Police Clearance, and NBI Clearance to support her petition.
- Proceedings and RTC Decision
- The RTC found the petition sufficient and ordered the publication of the petition in a newspaper of general circulation for three consecutive weeks.
- After trial, the RTC granted the petition on December 14, 2016:
- Ordered the Local Civil Registry of Magallanes, Cavite, to correct Merly's first name from "Merle" to "Merly."
- Ordered the correction of her date of birth from February 15, 1959 to November 26, 1958.
- Motion for Reconsideration and Appeal
- The Office of the Solicitor General (OSG) filed a motion for reconsideration, contesting the RTC’s jurisdiction and the failure to implead all interested parties.
- The RTC denied the motion.
- OSG then filed a petition for review on certiorari before the Supreme Court challenging:
- The RTC’s jurisdiction over the correction of the first name, arguing the error was clerical and subject to administrative correction under RA No. 9048, amended by RA No. 10172.
- The RTC’s grant of correction of date of birth, claiming failure to implead all persons with interest as required under Rule 108.
Issues:
- Whether the RTC has jurisdiction to correct the first name on the birth certificate when the error is clerical and can be corrected administratively under RA No. 9048, as amended by RA No. 10172.
- Whether the RTC erred in ordering correction of the date of birth without impleading all indispensable parties as required under Section 3, Rule 108 of the Rules of Court.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)