Case Summary (G.R. No. 203371)
Trial Court Jurisdiction and Ruling
RTC-La Trinidad, Benguet accepted jurisdiction over the petition under Rule 108, finding proper notice, publication and evidence. It ordered LCR-Itogon to amend the records and LCR-Carrangalan to cancel the second certificate as incident to the main relief.
Court of Appeals Affirmation
The CA held that correcting the first certificate and canceling the second were components of one in rem proceeding. Under ancillary jurisdiction, the RTC could resolve matters “incidental to” the principal action, avoiding multiplicity of suits.
Jurisdictional Issue on Review
The Republic argued the RTC-La Trinidad lacked jurisdiction over LCR-Carrangalan and that RA 9048 (amended by RA 10172) divested RTCs of authority on clerical corrections. Respondent invoked the rule against splitting causes of action.
Ancillary Jurisdiction Doctrine
Jurisdiction over the main case extends to all incidental matters. A court empowered to grant a principal remedy may also adjudicate necessary ancillary reliefs, even if those reliefs would independently require separate actions.
Administrative Remedies under RA 9048 and RA 10172
RA 9048 authorized administrative correction of clerical/typographical errors and first‐name changes without judicial order; RA 10172 later added sex and day/month corrections. Yet judicial remedy under Rule 108 remains available, especially when administrative procedures cannot address all errors or where administrative petitions were not first filed.
Supreme Court Ruling
The Supreme Court affirmed the CA. It held:
- RTC-La Trinidad validly exercised in rem jurisdiction to correct the main certificate and incidentally cancel the duplicate.
- RA 9048 (as amended) provides a primary administrative remedy but
Case Syllabus (G.R. No. 203371)
Facts of the Case
- Respondent Charlie Mintas (a.k.a. Shirley Mintas Felix) was born on October 1, 1976 in Itogon, Benguet.
- Two birth certificates exist:
- First certificate (LCR–Itogon, Benguet) erroneously recorded: first name “Shirley,” gender “female,” and father’s surname “Filex.”
- Second certificate (LCR–Carrangalan, Nueva Ecija) correctly recorded: first name “Charlie,” gender “male,” and father’s surname “Felix.”
- In subsequent transactions, respondent used the Nueva Ecija certificate but NSO-authenticated copies reflected the erroneous Itogon certificate.
Petition for Correction of Entries
- Filed under Rule 108 on July 30, 2007 with the Regional Trial Court (RTC), La Trinidad, Benguet.
- Prayed for:
- Correction of entries in LCR–Itogon certificate (first name, gender, father’s surname).
- Cancellation of the second birth certificate with LCR–Carrangalan, Nueva Ecija.
Republic’s Opposition
- Office of the Solicitor General moved to dismiss, arguing:
- RTC–La Trinidad had no jurisdiction over LCR–Carrangalan in Nueva Ecija.
- Cancellation of the second certificate should be pursued in a separate forum.
Proceedings and Evidence in the RTC
- Compliance with mandatory publication, posting, and service.
- Respondent testified and submitted:
- Both birth certificates.
- Medical certificate.
- Scrotal ultrasound confirming male sex.
Trial Court Ruling (July 23, 2009)
- Granted the petition in full:
- Ordered NSO and LCR–Itogon to amend entries: sex to MALE; first name to CHARLIE; father’s surname to FELIX.
- Directed LCR–Carrangalan, Nueva Ecija to cancel respondent’s second birth registration.
- Ordered dissemination of the decision to all concerned offices and parties.
Appeal to the Court of Appeals
- Republic appealed CA G.R. CV No. 94253, challenging jurisdiction over the second certificate.
- Respondent resisted, invok