Case Summary (G.R. No. 239584)
Background of the Case
The petitioner, Matron M. Ohoma, filed a petition before the Regional Trial Court (RTC) on March 26, 2014, seeking the cancellation of his first Certificate of Live Birth, issued on June 13, 1986, due to erroneous entries regarding his names. The petitioner also submitted a second Certificate of Live Birth issued in 2000, which he claimed accurately reflected his correct name—Matiorico Ohomna. The petitioner sought to retain the more recent certificate and cancel the earlier one.
RTC Proceedings
On May 14, 2014, the RTC issued an order recognizing the sufficiency of the petition and subsequently allowed the petitioner to present evidence ex-parte after an order of general default was issued. The court received various documents from the petitioner, including identification records, to substantiate the claim. On June 9, 2015, the RTC granted Ohoma’s petition, highlighting the erroneous entries on the first birth certificate and ordering the cancellation thereof.
Appeal to the Court of Appeals
Dissatisfied with the RTC's ruling, the Republic of the Philippines appealed to the Court of Appeals (CA), asserting that the first birth certificate was valid as it had been registered within the prescribed time and that, therefore, the remedy should have been a petition for correction of entries, as outlined under Rule 108 of the Rules of Court.
The CA's Decision
On February 1, 2018, the CA annulled the RTC’s decision, asserting that the first birth certificate was lawfully registered within the required 30-day period after birth, as mandated by Office of the Civil Registrar-General Administrative Order No. 1, Series of 1983. The CA ruled that the second birth certificate, hence, had no legal basis for validity and directed the filing of a correction petition for the first certificate instead.
Issue for Resolution
The central issue before the Court was whether the CA erred in annulling the RTC ruling that ordered the cancellation of the first birth certificate and the retention of the second.
Court's Ruling
The Supreme Court upheld the CA’s ruling, confirming that the petitioner’s birth was indeed reported within the mandated timeframe and thus, validly registered under the first birth certificate. Despite the petitioner’s claims regarding the inaccuracies of his name, the Court noted that the remedy sought could have been addressed under Rule 108, as the nature of the complaint pertained to the correction of erroneous entries rather than the outright invalidation of the first registration.
Evidence and Findings
The Court concluded that while the petitioner did provide some evidence support
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Case Information
- Citation: 853 Phil. 716; 116 OG No. 39, 6102 (September 28, 2020)
- G.R. No.: 239584
- Date: June 17, 2019
- Division: Second Division
- Petitioner: Matron M. Ohoma (Matiorico M. Ohomna)
- Respondents: Office of the Municipal Local Civil Registrar of Aguinaldo, Ifugao and Republic of the Philippines
- Decision by: Justice Perlas-Bernabe
Procedural History
- The case is an appeal from the Decision dated February 1, 2018, and the Resolution dated May 16, 2018, of the Court of Appeals (CA) in CA-G.R. CV No. 105591.
- The CA annulled the Resolution dated June 9, 2015, of the Regional Trial Court (RTC) of Alfonso Lista, Ifugao, Branch 15, in Special Proceedings Case No. 142-14.
Background Facts
- The petitioner filed a petition on March 26, 2014, to cancel his Certificate of Live Birth with Registry Number 45-86 (first birth certificate).
- Petitioner claimed:
- Birth Details: Born on May 13, 1986, in Aguinaldo, Ifugao.
- First Registration: Birth recorded belatedly on June 13, 1986, under the first birth certificate.
- Second Registration: Recorded on February 8, 2000, under Registry Number 2000-24 (second birth certificate).
- Errors: Claimed errors in the first birth certificate regarding his first name (Matron instead of Matiorico) and last name (Ohoma instead of Ohomna).
- Usage of Names: Used the names Matiorico and Ohomna in public and private transactions.
- Retention of Second Certificate: Requested that the second birth certificate be retained as it refle