Case Summary (G.R. No. L-20715)
Factual Background
The petitioners sought modifications to their birth certificates to reflect their current citizenship status as Filipino citizens and to adopt their father's new surname following his naturalization. Tiong Sim Go Bon King became a Filipino citizen on December 5, 1953, with his citizenship affirmed by his naturalization process concluding on December 15, 1955, when he took his oath. Subsequently, he was granted a change of name to Daniel C. Go, which became final on January 16, 1956. After the father's naturalization, the petitioners received identification certificates from the Bureau of Immigration indicating their status as Filipino citizens.
Procedural History
Initially, the local court granted the petition for the corrections sought by the petitioners based on an agreed stipulation of facts submitted by the parties. The government contested this decision on the grounds that the entries to be corrected were substantial and should not fall under the jurisdiction of Article 412 of the Civil Code, which permits only clerical amendments.
Legal Issues
The government's argument proposed that the changes requested by the petitioners constituted substantive corrections rather than clerical inaccuracies, thus altering their legal status. The oppositional stance claimed that correcting citizenship and surname would materially affect the status of the petitioners as legitimate children of Tiong Sim Go Bon King.
Court's Reasoning
The court rejected the government's claims, emphasizing that the requested changes were supported by indisputable evidence documenting the petitioners' legitimate status and citizenship. It was reaffirmed that the rights of minor children include the right to adopt their father’s surname, particularly after the father achieved naturalization, hence establishing their citizenship due to the provisions of Commonwealth Act No. 473, Section 15, as amended by Republic Act No. 530. Moreover,
...continue readingCase Syllabus (G.R. No. L-20715)
Case Citation
- 122 Phil. 651
- G.R. No. L-20715
- Date of Decision: November 27, 1965
Parties Involved
- Petitioners and Appellees: Henry Tiong, Robert Tiong, and George Tiu
- Opposer and Appellant: Republic of the Philippines
Background of the Case
- Petitioners sought to amend their birth certificates held by the local civil registrar to reflect their current citizenship and surnames.
- The government opposed the petition, arguing that the proposed changes were substantial and controversial, and thus could not be made under Article 412 of the new Civil Code.
Stipulation of Facts
- Petitioners are the legitimate children of Tiong Sim Go Bon King, also known as Benita Tiu.
- Birth dates:
- Henry Tiong: April 20, 1939
- Robert Tiong: April 12, 1947
- George Tiu: February 19, 1949
- Tiong Sim Go Bon King became a Filipino citizen on December 5, 1953, through a decree issued by the Court of First Instance of Manila, with the naturalization finalized on December 15, 1955.
- Following his naturalization, Tiong Sim applied for a name change to Daniel C. Go, which was granted and became final.
- After the naturalization, the Bureau of Immigration issued identification certificates reflecting the petitioners' citizenship as Filipino.