G.R. No. 211435 - Tan vs. Office of the Local Civil Registrar of the City of Manila

On September 7, 2011, petitioner Ramon Corpus Tan filed a Petition for Correction of Entry before the Regional Trial Court (RTC) Manila, Branch 27, under Rule 108 of the Revised Rules of Court, seeking correction of his name in his Certificate of Live Birth.
Upon realizing the failure to implead the Office of the Local Civil Registrar of Manila (LCR Manila) and the National Statistics Office (now Philippine Statistics Authority or PSA) as respondents, petitioner filed an Ex-Parte Motion to Admit Amended Petition and amended the petition accordingly on September 30, 2011.

Petitioner was born on November 13, 1965, at St. Paul Hospital in Manila; his birth was duly registered in Manila's civil registry.
His real name is "Ramon Corpuz Tan," but the Certificate of Live Birth wrongly entered it as "Ramon Corpus Tan Ko."
The error was due to inadvertence of hospital personnel; specifically, "Ko," the first name of petitioner’s father, was mistakenly included in the surname.
The mistake was only discovered after petitioner had children.

Diploma, certification of kindergarten completion, secondary report card from Philippine Chung Hua School;
COMELEC Voter's ID and affidavit;
BIR Tax Identification Number and ID;
Community Tax Certificate (Quezon City);
Certificate of Marriage to Maria Teresa Gatuz.

Petitioner’s judicial affidavit;
Certificate of Live Birth showing name as "Ramon Corpus Tan Ko";
Various government IDs (BIR, firearm license, PhilHealth) indicating "Tan Ramon Corpuz" or variants;
Certificate of Marriage and petitioner’s children's birth certificates.

On November 23, 2011, hearing was conducted; petitioner testified and was cross-examined.
On December 27, 2011, the RTC dismissed the petition, ruling that the correction was substantial and not merely clerical, requiring an adversarial proceeding.
RTC noted that petitioner failed to implead his mother, Trinidad Corpuz, who was the informant in the birth certificate and was affected by the correction.
Petitioner’s motion for reconsideration was denied on May 18, 2012.

Petitioner appealed to the CA, which affirmed the RTC Orders on September 27, 2013.
The CA held that the correction from "Tan Ko" to "Tan" is a substantial change affecting the identity of petitioner’s father and that proper parties, especially petitioner’s mother, were not impleaded.
The CA found petitioner’s evidence insufficient to prove the error, emphasizing the need for testimony of petitioner’s mother or presentation of siblings’ birth certificates.
Petitioner’s motion for reconsideration was denied on February 24, 2014.

Petitioner filed this Petition for Review on Certiorari before the Supreme Court assailing the CA decisions.
Petitioner insists the error was clerical and did not require a full adversarial proceeding.
The Office of the Solicitor General (OSG) adopted the appellee’s brief, agreeing that petitioner failed to prove his cause of action despite substantial compliance with procedure.

Whether the trial and appellate courts erred in ruling that the petitioner failed to observe the requirements of an adversarial proceeding under Rule 108 when seeking correction of entry in his birth certificate.