Facts:

• Republic of the Philippines v. Sali (G.R. No. 206023), decided April 3, 2017.
• Petition Filed: Lorena Omapas Sali filed a Verified Petition for Correction of Entry under Rule 108 with RTC, Branch 14, Baybay City, Leyte.
• Corrections Sought: Sali sought to correct her first name from "Dorothy" to "Lorena" and her birth date from "June 24, 1968" to "April 24, 1968."
• Evidence Provided: Her Baptismal Certificate and her Certificate of Live Birth.
• RTC Decision: The RTC granted the petition, ordering corrections by the Local Civil Registrar of Baybay City and the National Statistics Office.
• Republic's Appeal: The Republic, through the OSG, appealed, arguing the petition should have been under Rule 103 and Sali failed to exhaust administrative remedies.
• Court of Appeals Decision: The Court of Appeals affirmed the RTC's decision.
• Supreme Court Review: The Republic sought a review on certiorari before the Supreme Court.

Issue:

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Ruling:

• Partial Grant: The Supreme Court partially granted the petition.
• Affirmation with Modification: Affirmed the decision of the Court of Appeals with modification.
• First Name Correction Dismissal: Dismissed the petition for the correction of Sali's first name without prejudice to its filing with the local civil registrar....(Unlock)

Ratio:

• Rule 108 vs. Rule 103: The Court held that Sali's petition was for the correction of clerical errors under Rule 108, not a change of name under Rule 103, as there was no intention to change her name but merely to correct a clerical error.
• R.A. No. 9048: Republic Act (R.A.) No. 9048, effective when Sali filed her petition in 2008, mandates that corrections of clerical errors and first names be addressed administratively.
• Judicial Intervention: Judicial intervention is warranted only if the administrative petition is denied.
• RTC's Error: The RTC should have dismissed the petition for the first name correction due to failure to exhaust administrative ...continue reading