Case Summary (G.R. No. 208005)
Factual Antecedents
Joel and Carmen Borromeo filed a verified petition for the adoption of Karen on May 26, 2005. On June 27, 2006, the RTC of Marikina City approved the adoption, declaring Karen as the legitimate child of the Borromeos and mandating corrections in her civil registry records. Following the court's decision, it became apparent that Karen's birth was registered in both the Quezon City and Caloocan City civil registries, leading to complications in executing the adoption decree.
Ruling of RTC of Marikina City
The RTC of Marikina City issued a decision on June 27, 2006, that declared Karen as the legitimate heir of Joel and Carmen Borromeo. The court ordered several actions to be taken by the City Civil Registrars of both Quezon City and Caloocan City regarding the registration of Karen's birth. However, when the petitioners approached the Quezon City Registrar on July 12, 2006, they were instructed to cancel the birth registration in Caloocan City, which led the petitioners to file a Petition for Cancellation at the RTC of Caloocan.
Ruling of RTC of Caloocan City
On May 23, 2012, the RTC of Caloocan City issued an order correcting entries in Karen's birth certificate but did not cancel the registration as requested. This created a hurdle in executing the adoption decision made by the RTC of Marikina City, as the latter had directed the Quezon City Registrar to implement the decision without addressing the duplicate registration in Caloocan City.
Motion to Correct and Subsequent Orders
The petitioners filed a motion on February 19, 2013, requesting the RTC of Marikina City to correct its decision to reference the City Civil Registrar of Caloocan City instead of Quezon City. However, this request was denied on May 23, 2013, based on the grounds that the June 27, 2006 decision had become final and immutable, thus not subject to alteration. The RTC also pointed out the absence of any recognized exceptions to the rule of immutability of judgments.
Present Petition
Unwilling to accept the denial, the petitioners filed for a petition for review on certiorari on August 1, 2013. They contended that adoption proceedings and civil registry corrections fall under special proceedings, arguing that the Rules of Court regarding immutability of judgments should not strictly apply in this context. The Office of the Solicitor General, which commented on the case, agreed that special proceedings allow for some flexibility.
Court's Ruling
The Supreme Court found that the case warranted an exception to the doctrine of immutability of judgment due to new facts resulting from the duplicate registration of Karen's birth. It cited established jurisprudence allowing for the executi
...continue readingCase Syllabus (G.R. No. 208005)
Introduction
- This syllabus outlines the case regarding the adoption of Karen Herico Licerio, involving petitioners Joel H. Borromeo and Carmen H. Borromeo.
- It covers the background, procedural history, rulings from the lower courts, and the Supreme Court's final decision.
Factual Antecedents
- Joel H. Borromeo and Carmen H. Licerio are a married couple with two legitimate children.
- They sought to adopt Karen Herico Licerio, the illegitimate daughter of Carmen.
- On May 26, 2005, they filed a verified Petition for Adoption with the RTC of Marikina City.
Ruling of the RTC of Marikina City
- On June 27, 2006, the RTC granted the adoption, declaring Karen a legitimate daughter of the petitioners.
- The decision included specific directives regarding:
- Karen's recognition as a legitimate and legal heir.
- The name change to Karen Licerio Borromeo.
- Procedures for the City Civil Registrar concerning the adoption decree.
Implementation Challenges
- On July 12, 2006, the petitioners faced complications when attempting to implement the RTC's decision.
- They discovered that Karen's birth was registered in both Quezon City and Caloocan City, necessitating the cancellation of the latter's registration.
- The petitioners filed a Petition for Cancellation in the RTC of Caloocan City.
Ruling of the RTC of Caloocan City
- On May 23, 2012, the Caloocan court ordered corrections to the Certificate of Live Birth but