G.R. No. 206023 - Republic vs. Sali

Lorena Omapas Sali (Sali), a Filipino resident of Baybay City, Leyte, filed a Verified Petition for Correction of Entry under Rule 108 of the Rules of Court before the Regional Trial Court (RTC) on November 26, 2008.
Sali alleged that there were errors in her Certificate of Live Birth: her first name was erroneously recorded as "Dorothy" instead of "Lorena," and her date of birth was recorded as "June 24, 1968," instead of "April 24, 1968."
She submitted supporting documents including her Baptismal Certificate, Certificate of Live Birth (with erroneous entries), Certification from Local Civil Registrar, Certificate of Marriage, and Postal Identity Card.
Sali claimed to have used the name "Lorena A. Omapas" and the date "April 24, 1968" her entire life, and that the petition was not meant to avoid civil/criminal liability or affect hereditary succession, but to correct the records.

Sali complied with the jurisdictional requirements, and evidence was received through a court commissioner.
On February 23, 2010, the RTC Branch 14, Baybay City, Leyte, granted the petition, ordering correction of her first name from "Dorothy" to "Lorena" and her birth date from "June 24, 1968" to "April 24, 1968."
The Local Civil Registrar of Baybay City and the National Statistics Office were instructed to effect the corrections upon finality of the decision and payment of legal fees.

The Republic of the Philippines, through the Office of the Solicitor General (OSG), appealed the RTC decision on March 24, 2010, arguing lack of jurisdiction due to omission of Sali’s aliases in the petition’s title and order setting the petition for hearing.
The Court of Appeals (CA) denied the appeal on February 11, 2013, ruling:

No evidence showed that Sali had any alias other than “Lorena.”
Sali complied with procedural requirements and gave the Republic the opportunity to contest.
The correction of first name would avoid confusion and was not shown to be for fraudulent purposes or against public interest.

The Republic filed a petition for review under Rule 45, raising two principal arguments:

The CA erred in applying Rule 108 instead of Rule 103 of the Rules of Court, thereby dispensing with the requirement to state respondent’s aliases in the petition title.
Sali failed to exhaust administrative remedies under Republic Act No. 9048 before filing the judicial petition.

Whether the petition for correction of first name and birth date should be governed by Rule 108 (Correction of Entries) or Rule 103 (Change of Name) of the Rules of Court.

Whether the respondent was required to exhaust administrative remedies provided under Republic Act No. 9048 before filing the petition for correction of her first name.

Whether the correction of the birth date entry is covered or excluded by administrative procedures under R.A. No. 9048 or its amendment, R.A. No. 10172.

Whether the trial court had jurisdiction over the petition filed by the respondent.