Case Summary (G.R. No. 241369)

Background of the Case

• Parties Involved: Sasha M. Cabrera (Petitioner) vs. Philippine Statistics Authority, Office of the Consul General, Philippine Embassy, Kuala Lumpur, and Office of the Solicitor General (Respondents).
• Nature of the Petition: Review on certiorari of the RTC's Orders dismissing the petition to correct Petitioner’s year of birth and cancel her second Report of Birth.

Facts of the Case

• Birth Registration: Petitioner claims she was born on July 20, 1989, but her birth was reported late, resulting in incorrect registration of July 20, 1980.
• Multiple Registrations: Her mother registered the birth twice, leading to complications in obtaining official documents.
• Prior Legal Proceedings: A previous petition to cancel the first Report of Birth was granted by RTC-Br. 17 but later reversed by the Court of Appeals.

RTC-Br. 14 Ruling

• Dismissal of Petition: The RTC-Br. 14 dismissed the re-filed petition due to improper venue, asserting that it should have been filed in Quezon City where the PSA is located, not in Davao City.
• Petitioner’s Motion for Reconsideration: This was denied, prompting the appeal to the Supreme Court.

Legal Issue

• Core Question: Whether the RTC-Br. 14 erred in dismissing the petition based on improper venue.

Court’s Ruling

• Decision: The Supreme Court found the petition meritorious, stating that venue is procedural and can be waived.

Legal Principles Established

• Venue vs. Jurisdiction: Venue is procedural, while jurisdiction is conferred by law. A party’s objection to venue must be made at the earliest opportunity.

• Court's Authority: Courts cannot dismiss cases motu proprio (on their own accord) for improper venue absent an objection raised by the parties.

Key Definitions

• Venue: The geographical location for the trial of a case.
• Jurisdiction: The authority of a court to hear and decide a case, governed by law.

Important Procedures and Requirements

• Filing a Petition: A petition for correction or cancellation of civil registry entries must follow Rule 108 of the Rules of Court.
• Objection to Venue: Must be raised in a motion to dismiss or answer; otherwise, it is deemed waived.

Relevant Timeframes

• Initial Birth Reporting: Birth was reported on August 27, 2008, and registered by the PSA on January 29, 2009.
• RTC Decision: Previous decisions and motions occurred over several years, culminating in the current ruling.

Consequences of Misapplication

• Dismissal Errors: The RTC-Br. 14's dismissal was reversed, allowing the case to proceed in the proper venue, emphasizing the importance of adhering to procedural norms.

Key Takeaways

• The Supreme Court clarified that:
  • Venue is a procedural issue and not a jurisdictional one.
  • Courts cannot dismiss cases on their own for improper venue w
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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 cancellation of her first Report of

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