G.R. No. 186400 - Bolos vs. Bolos

The case involves the correction of an entry in the birth certificate of Arthur Tan Manda.
The birth certificate erroneously recorded the citizenship of his parents as “Chinese,” which, if uncorrected, would imply that the respondent too is a Chinese citizen.
Respondent asserted that his father, Siok Ting Tan Manda, is a Filipino citizen by birth while his mother, Chin Go Chua Tan, is a Filipino citizen by marriage.
To support his claim, respondent presented Identification Certificates issued by the then Commission on Immigration and Deportation (CID) that recognized his parents as Filipino citizens.

The Regional Trial Court (RTC), Branch 6, Cebu City, in its January 15, 2004 Decision, granted the petition for correction of the birth certificate based on the evidence submitted.
Aggrieved by the RTC ruling, the Republic of the Philippines (petitioner) appealed to the Court of Appeals (CA).
The CA, in its January 4, 2012 Decision, affirmed the RTC ruling, holding that the publication of the notice of hearing and the service of notices were sufficient to constitute an adversarial proceeding.
After the issuance of the CA decision, the case was elevated to the Supreme Court through a Petition for Review on Certiorari by the petitioner.

The petitioner in the case is the Republic of the Philippines, contesting the correction of the birth certificate.
The respondent is Arthur Tan Manda, whose petition sought the correction of his parents’ citizenship entries from “Chinese” to “Filipino.”
Owing to his death on June 1, 2011, Arthur Tan Manda was substituted by his wife, Arlinda D. Manda, who continued the suit and defended the sufficiency of the notice given through publication.
The case also brings to light the issue of the impleading of indispensable parties, namely the respondent’s parents and siblings, whose interests would be affected by the alteration of the birth certificate entries.

Petitioner argued that the changes in the record—being substantial because of their potential effects on the citizenship status of the parents and siblings—required that all concerned parties be notified or impleaded, rather than sufficing with a notice to the Local Civil Registrar alone.
Respondent (and subsequently his wife) relied on the publication of the notice of hearing and the submission of Identification Certificates by the then CID to prove the Filipino citizenship of his parents.
The core factual dispute pertained to whether the evidence adduced was adequate and whether proper procedural notice to all interested parties was effected, as mandated by law.

Should the petition be denied on the ground that the petitioner failed to implead all indispensable parties, notably the respondent’s parents and siblings, in the correction proceeding?
Whether the evidence submitted—specifically the Identification Certificates issued by the then CID—sufficiently proves that the respondent’s parents are indeed Filipino citizens, thereby justifying the correction of the birth certificate entries?
Does the publication of the notice of hearing, in lieu of direct notification to all interested parties, satisfy the due process requirements in cases involving substantial and controversial alterations to the civil registry?