Case Summary (G.R. No. L-9526)
Petitioner's Claims
In his petition, William H. Brown sought to amend Henrietta’s birth certificate by changing her name to Henrietta Piconada Brown, altering her nationality from Filipino to American, and providing details about himself as her father. He invoked Article 412 of the New Civil Code, which regulates changes in civil registries, and requested that the Civil Registrar of Manila make these amendments to reflect his acknowledgment of paternity.
Government's Opposition and Court Decision
The Solicitor General filed an opposition to Brown’s petition on behalf of the Republic of the Philippines. The Court of First Instance granted Brown's petition except for the nationality change, ordering the Civil Registrar to affix the surname "Brown" to Henrietta's name and to enter Brown's information under the father’s section of the birth certificate. The government appealed this decision, primarily invoking the ruling in Ty Kong Tin vs. Republic of the Philippines, which emphasized that Article 412 pertains to clerical corrections rather than substantive changes pertaining to civil status or citizenship.
Legal Principles and Judicial Reasoning
The appellate court noted that the entries made by the Local Civil Registrar reflected the information provided by Matea Piconada at the time of Henrietta's birth. Since Matea had declared the father's identity as unknown, this complied with Article 280 of the Civil Code, which prohibits revealing identifying information about the child's other parent when recognition occurs separately. The court asserted that allowing the changes requested, especially regarding Henrietta’s legitimacy or citizenship status, would retroactively alter facts recorded at the time of her birth and sanction a non-judicial recognition
...continue readingCase Syllabus (G.R. No. L-9526)
Case Background
- On October 15, 1935, a baby girl named Henrietta Piconada was born at the Maternity and Children's Hospital in Manila, Philippines.
- The child's mother, Matea Piconada, declared the father to be unknown, which was recorded in the hospital report, local civil registrar, and on the birth certificate (Exhibit A).
- Nearly twenty years later, on June 6, 1955, William H. Brown filed a petition in the Court of First Instance of Manila asserting that Henrietta Piconada is his daughter.
- Brown stated that Henrietta had been registered and known as Henrietta Brown since she began school and that she had been under his custody for education and support with her mother's knowledge and consent.
Petition Details
- Brown's petition sought to amend the birth certificate of Henrietta Piconada to reflect the following changes:
- Change the name from "Henrietta Piconada" to "Henrietta Piconada Brown."
- Change the nationality from "Filipino" to "American."
- Complete the father's details, including name, residence, citizenship, age, birthplace, civil status, religion, and occupation as specified in his petition.
Government Opposition
- The Solicitor General opposed the petition on behalf of the Government.
- After necessary proceedings, the Court of First Instance granted Brown's petition, except for the nationality amendment.