Case Summary (G.R. No. 137172)
Antecedents and Procedural History
Oliver and Roselyn Boquiren were born out of wedlock to Oscar D. Boquiren and Rosalinda B. Macaraeg. Their births were registered belatedly in 2002, shortly after their parents’ marriage. Following this marriage, affidavits of legitimation executed by their parents were annotated in their certificates of live birth (COLB), enabling the use of their father’s surname. In 2015, the Philippine Statistics Authority (PSA) informed them that their legitimation could not be effected due to Oscar’s prior valid marriage to another woman in 1987, thus rendering the second marriage void for bigamy. Consequently, respondents filed a petition with the Regional Trial Court (RTC) for correction of entries in their COLBs, seeking cancellation of the affidavits of legitimation and annotation of affidavits of acknowledgment executed by their father.
RTC and Court of Appeals (CA) Rulings
The RTC granted respondents’ petition, ordering cancellation of the annotations regarding legitimation and directing the annotation of the affidavits of acknowledgment. It ruled that due to the bigamous nature of the parents’ marriage, legitimation was impossible. The Court of Appeals affirmed the RTC decision, emphasizing compliance with Rule 108’s adversarial proceeding requirements, the validity of the PSA certification, and the principle that correction of substantial registry errors is allowed through this process. The CA held that the RTC had jurisdiction to determine the validity of the marriage and to correct the civil registry entries accordingly, invoking jurisprudence that validity of marriage may be collaterally questioned if essential to the case.
Petitioner's Arguments on Jurisdiction and Legitimacy
Petitioner contended that the RTC lacked jurisdiction under Rule 108 to nullify marriages or rule on legitimacy and filiation, which must be settled in a direct proceeding under the Family Code and relevant Supreme Court rules (A.M. No. 02-11-10-SC). It argued that the decision effectively declared the respondent parents’ marriage void ab initio and allowed respondents to impugn their own legitimated status improperly without any prejudiced third party or direct action. The petitioner viewed the RTC’s ruling as an illegitimate collateral attack on legitimacy and marriage validity through a Rule 108 petition.
Respondents’ Position on Correction of Entries
Respondents argued they did not seek to directly annul their parents’ marriage but merely to correct erroneous entries in their birth certificates that inaccurately reflected their status as legitimated children, contrary to the fact of their parents’ void marriage for bigamy. They maintained that the PSA’s certification negated the validity of the later marriage and that the correction was necessary to accurately reflect their status as illegitimate children, supported by the father’s acknowledgment affidavit which allowed them to retain the paternal surname.
Supreme Court’s Analysis on Rule 108 Jurisdiction
The Court ruled that the RTC does not have jurisdiction under Rule 108, which governs cancellation or correction of civil registry entries, to determine the validity of marriages, or to decide on legitimacy and filiation. Rule 108 allows correction of errors in the civil registry but cannot be used to collaterally attack marriage validity or legitimacy status. The Supreme Court reiterated its rulings in Braza v. City Civil Registrar, Miller v. Miller, and Ordoña v. Local Civil Registrar, holding that issues of marriage validity and legitimacy can only be adjudicated in direct actions by proper parties within the prescribed period under the Family Code. The Court distinguished these cases from Republic v. Kho, clarifying that correction of registry entries concerning marriage can be made via Rule 108 only when it is certain that no marriage existed, unlike this case where a marriage was in fact celebrated.
On Collateral Attack of Legitimation and Proper Parties
The Court emphasized that legitimation confers upon children the full rights of legitimate children and that their status cannot be collaterally impugned via a Rule 108 proceeding. Under Article 182 of the Family Code, legitimation may be challenged only by those prejudiced in their rights, usually the legal heirs, within a certain period, and through direct judicial action. Respondents, as the legitimated children, are not proper parties to challenge their own legitimation. Allowing them to do so would not only be legally untenable but also produce absurd results, depriving them of rights previously recognized and enjoyed.
On Authority of RTC to Rule on Bigamous Marriage Validity in Rule 108 Petition
The Court rejected the CA’s reliance on cases permitting collateral attack on marriage validity in other types of proceedings, clarifying that none of those cases involved petitions under Rule 108 for correction of civil registry entries. The Court expressly reaffirmed that Rule 108 proceedings are not proper venues for invalidating marriages or ruling upon legitimacy and filiation, which must be first established in proper judicial proceedings. The case of Fujiki v. Marinay was cited to demonstrate that recognition of foreign judgments annuling marriages is an exception, but this does not apply to attempts to nullify marriage through registry corrections in domestic cases.
Final Disposition
The Supreme Court granted the petition, reversed and set aside the decisions of the Court of Appeals and the RTC ruling in favor of respondents, and dismissed the respondents’ petition for correction of entries in their birth certificates. The Local Civil Registry was directed to annotate in respondents’ birth certificates the PSA certification evidencing Oscar’s prior existing marriage to Gloria Erese Pangilinan in 1987. The Court maintained that respondents’ legitimated status could be properly challenged only by the appropriate parties and through the proper judicial process, and that the State’s civil registry must reflect the existing lawful marital facts until such time.
Dissenting Opinion Highlights
Justice Singh dissented, emphasizing strict compliance with Rule 108’s adversarial requirements in the case, noting that respondents complied by impleading interested parties and giving notice through publication. He argued that the RTC’s role was not to nullify the parents’ marriage but merely to correct registry entries in light of the PSA certification on prior marriage, reflecting a void second marriage and invalid legitimation. He highlighted jurisprudence that allows correction of substantial and controversial errors affecting legi
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Case Syllabus (G.R. No. 137172)
Facts and Procedural History
- Respondents Oliver M. Boquiren and Roselyn M. Boquiren, siblings born out of wedlock in 1997 and 1999 respectively, were belatedly registered in the Local Civil Registry (LCR) of Malasiqui, Pangasinan in 2002.
- Their parents, Oscar D. Boquiren and Rosalinda B. Macaraeg, married after their births on April 18, 2002. Following this, affidavits of legitimation executed by their parents led to annotations in the siblings’ certificates of live birth (COLBs) reflecting their legitimated status.
- In 2015, they were informed by the Philippine Statistics Authority (PSA) that their legitimation could not be effected due to Oscar’s prior marriage to Gloria Erese Pangilinan in 1987, which had not been dissolved.
- As a result, respondents filed a petition for correction of entries in their COLBs to cancel the annotations of legitimation and instead substitute them with affidavits of acknowledgment executed by Oscar, allowing them to continue using his surname.
- The RTC granted their petition, ordering cancellation of the affidavits of legitimation and annotation of the affidavits of acknowledgment.
- The Republic of the Philippines, through the Office of the Solicitor General (OSG), opposed the petition, arguing that the RTC lacked jurisdiction to nullify marriages or rule on legitimacy through a Rule 108 proceeding.
- The Court of Appeals (CA) affirmed the RTC decision, holding that the correction of substantial errors in the civil registry is allowed in Rule 108 proceedings following proper adversarial process.
- Petitioner elevated the case to the Supreme Court via a petition for review on certiorari.
Issue Presented
- Whether the Court of Appeals erred in affirming the Regional Trial Court’s grant of the petition for correction of entries in respondents’ certificates of live birth under Rule 108, particularly in ruling on the validity of the marriage of respondents’ parents and their legitimacy.
Arguments of the Parties
Petitioner (Republic of the Philippines):
- The RTC and CA lacked jurisdiction under Rule 108 to declare void a marriage or to rule on legitimacy and filiation.
- Declaring the marriage void ab initio and changing respondents’ status to illegitimate without a direct proceeding violates the mandate of Family Code and procedural rules on nullity of marriage.
- Respondents improperly impugn their own legitimated status absent a direct action initiated by interested or prejudiced parties under Article 182 of the Family Code.
- The correction-of-entries petition cannot substitute direct actions required for declaration of nullity or legitimation challenges.
Respondents Oliver and Roselyn:
- Their petition merely seeks correction of erroneous entries reflecting a bigamous marriage of their parents that contradicts the facts as certified by PSA.
- The proceeding properly followed the Rule 108 adversarial process, including notice and participation of relevant parties.
- They are not impugning their filiation or legitimacy but seeking the accurate reflection of their legal filiation based on the invalidity of their parents’ marriage due to bigamy.
- Government has no interest in protecting a void and bigamous marriage.
Supreme Court’s Ruling and Reasoning
- The Court granted the petition, ruling the RTC lacked jurisdiction under Rule 108 to pass upon the validity of a marriage and the legitimacy status of children.
- Rule 108 pro