Case Summary (G.R. No. 241369)

Background of the Case

• Petitioner Sasha M. Cabrera was born on July 20, 1989, in Lahad Datu, Sabah, Malaysia.
• Due to the distance from the Philippine Embassy, her birth was reported late, on August 27, 2008.
• The National Statistics Office (now Philippine Statistics Authority) recorded her first Report of Birth on January 29, 2009, with an incorrect date of birth listed as July 20, 1980.
• Instead of correcting the error, her mother registered her birth a second time, leading to a second Report of Birth recorded in March 2010.
• The existence of two Reports of Birth caused difficulties for the petitioner in obtaining official documents, prompting her to file a petition for cancellation of the first Report of Birth.

Proceedings in the Regional Trial Court

• The initial petition for cancellation was filed before RTC of Davao City, Branch 17, and was granted on November 19, 2012, after due process.
• The Office of the Solicitor General (OSG) filed a motion for reconsideration, which was denied.
• The OSG subsequently appealed to the Court of Appeals (CA), which ruled on February 11, 2016, that the first Report of Birth could not be subject to a second registration and that the proper recourse was to file a petition for correction of entry under Rule 108 of the Rules of Court.

Dismissal by RTC-Br. 14

• Petitioner re-filed her petition to correct her year of birth and cancel the second Report of Birth, which was assigned to RTC-Br. 14.
• On September 15, 2017, RTC-Br. 14 dismissed the petition, citing improper venue as the Office of the Consul General acted as the civil registry.
• The court held that the petition should have been filed in Quezon City, where the PSA is located, rather than in Davao City.

Legal Arguments Presented

• The petitioner contended that venue is procedural and not jurisdictional, arguing that improper venue does not equate to lack of jurisdiction.
• She asserted that the RTC-Br. 14 erred in dismissing the case without an objection from the respondents regarding venue.
• The OSG supported the petitioner’s view, stating that venue is a matter of convenience and should not restrict access to the courts.

Court's Ruling on Venue

• The Court found the petition meritorious, emphasizing that venue is procedural and can be waived.
• It clarified that objections to venue must be rais...continue reading

Case Syllabus (G.R. No. 241369)

Case Background

• Petitioner: Sasha M. Cabrera
• Respondents: The Philippine Statistics Authority (formerly National Statistics Office), Office of the Consul General, Philippine Embassy, Kuala Lumpur, and the Office of the Solicitor General
• Case Reference: G.R. No. 241369, June 03, 2019
• Jurisdiction: Second Division of the Supreme Court of the Philippines
• Initial proceedings commenced with a petition for review on certiorari challenging the Orders of the Regional Trial Court (RTC) of Davao City, Branch 14.

Facts of the Case

• Petitioner Cabrera was born on July 20, 1989, in Zuba Estate, Lahad Datu, Sabah, Malaysia.
• Due to geographical distance, her birth was reported only on August 27, 2008, to the Philippine Embassy in Kuala Lumpur.
• The National Statistics Office (now PSA) recorded the first Report of Birth on January 29, 2009, under Registry Number 2009-4580024.
• A clerical error led to her date of birth being recorded as July 20, 1980, prompting her mother to register a second Report of Birth in March 2010, under Registry Number 2010-4580208.
• The existence of two Reports of Birth created complications for the petitioner in obtaining official documents.

Prior Proceedings

• Cabrera filed a petition for can...continue reading