G.R. No. L-20715 - Tiong vs. Republic

The petitioners—Henry Tiong, Robert Tiong, and George Tiu—sought to correct or annotate entries in their certificates of birth on record with the local civil registrar.
The corrections pertained to their present citizenship status as Filipino and the adoption of new surnames reflecting their father's changed name.

The petitioners are the legitimate children of Tiong Sim @ Go Bon King, who later became known as Daniel C. Go following a judicial decree.
Tiong Sim @ Go Bon King originally was a Chinese citizen who acquired Filipino citizenship:

He became a Filipino by virtue of a decree issued by the Court of First Instance of Manila on December 5, 1953, which became final and executory on December 15, 1955, the day he took his oath.
Subsequently, he applied for a change of name from his original name to Daniel C. Go, with the decision becoming final (January 16, 1956).

The change of name, along with his naturalization, was duly annotated on his naturalization certificate after obtaining the requisite judicial authority.

Henry Tiong was born on April 20, 1939.
Robert Tiong was born on April 12, 1947.
George Tiu was born on February 19, 1949.
All petitioners were minors at the time their father underwent naturalization and subsequent name change.

Following the naturalization of their father, the petitioners were issued identification certificates by the Bureau of Immigration which recorded their citizenship as Filipino.
The birth certificates in the civil registry, however, still reflected the details as they were originally recorded at birth—prior to the father’s naturalization and name change.
The petition, supported by undisputed, indubitable documentary evidence, sought the necessary annotations to update these records.

The court a quo, relying on the undisputed facts and documentary evidence, granted the petition for the corrections or annotations in the birth certificates.
The government opposed the petition, arguing that the changes were substantial and controversial because they involved alterations stemming from judicial proceedings rather than mere clerical errors.
The contention centered on whether such judicially effected changes should affect the entries in the birth certificates.

Whether the petitioners are entitled to seek annotations or corrections in their birth certificates to reflect their true civil status and citizenship, as indicated by subsequent judicial proceedings in connection with their father’s naturalization and change of name.

The issue involves determining if the changes sought are merely clerical or if they substantially affect their legal status.
Whether annotations based on judicial proceedings that occurred after the issuance of the original birth certificates can be recorded in the civil registry.

Whether the corrections or annotations, even if reflecting judicial proceedings post-birth, are supported by indisputable documentary evidence and statutory provisions.

The government argued that the entries to be changed are substantial, controversial, and not subject to correction under Article 412 of the new Civil Code.
The court had to decide if the documentary evidence, such as the identification certificates from the Bureau of Immigration and the naturalization decree, sufficiently justified the update in the civil registry.