Ohoma v. Office of the Municipal Local Civil Registrar of Aguinaldo
REITERATIONFacts
The Antecedents: Petitioner Matron M. Ohoma (also known as Matiorico M. Ohomna) sought the cancellation of his first Certificate of Live Birth, registered on June 13, 1986, due to erroneous entries. He claimed his first name was incorrectly recorded as Matron instead of Matiorico, and his last name as Ohoma instead of Ohomna. He asserted that he has consistently used Matiorico Ohomna in his public and private dealings and that a subsequent birth certificate, registered on February 8, 2000, accurately reflects his true details. Procedural History: The petitioner filed a petition before the Regional Trial Court (RTC) of Alfonso Lista, Ifugao, seeking the cancellation of his first birth certificate. The RTC granted the petition, ordering the cancellation of the first birth certificate due to the errors causing confusion. The Republic of the Philippines appealed this decision to the Court of Appeals (CA), arguing that the second registration was invalid and that the proper remedy for errors was a petition for correction of entries under Rule 108 of the Rules of Court. The CA annulled the RTC's resolution, ruling that the second registration was invalid as the birth was already lawfully registered within the prescribed period, and that the first birth certificate should have been upheld, with any corrections made under Rule 108. The Petition: Petitioner seeks review on certiorari of the CA's decision and resolution. He contends that the CA erred in annulling the RTC's order to cancel his first birth certificate. While the initial petition before the RTC sought cancellation of the first birth certificate and retention of the second, the ultimate aim was to correct the erroneous entries in his name. The petitioner argues that his case falls under Rule 108, and the RTC had jurisdiction to grant the relief sought, including the general prayer for other just and equitable reliefs, given that he complied with the procedural requirements. However, the Supreme Court ultimately denied the petition, finding insufficient evidence to establish the correct last name and noting discrepancies in the mother's signature on the two birth certificates.
Issue(s)
Whether the Court of Appeals committed reversible error when it annulled and set aside the RTC ruling ordering the cancellation of petitioner's first birth certificate, considering the validity of the second birth certificate and the proper remedy for erroneous entries. Whether the RTC had jurisdiction to grant the petition for cancellation and retention of the second birth certificate, including the prayer for other just and equitable reliefs, and whether it could have resolved the claim for correction under Rule 108. Whether the petitioner sufficiently established the correct first and last names through competent evidence for correction.
Ruling
The petition is DENIED. The Decision and Resolution of the Court of Appeals are SET ASIDE. A new judgment is entered ORDERING the Local Civil Registrar of Aguinaldo, Ifugao and the Philippine Statistics Authority to cancel petitioner Matron M. Ohoma's Certificate of Live Birth with Registry Number 2000-24.
Ratio Decidendi
On the validity of the second birth certificate and the proper remedy: The Court affirmed the CA's finding that the second birth certificate (Registry Number 2000-24) is void. Petitioner's birth was already registered on June 13, 1986, within the 30-day period required by law. Therefore, a subsequent registration of the same birth is invalid. The Court reiterated that the proper remedy for erroneous entries in a validly registered birth certificate is not cancellation and re-registration, but a petition for correction of entries under Rule 108 of the Rules of Court. On the RTC's jurisdiction and potential resolution under Rule 108: The Court noted that while the petition prayed for cancellation, the ultimate objective was to correct erroneous entries, which falls under Rule 108. The RTC, having acquired jurisdiction under Rule 108 and considering the prayer for "other reliefs just and equitable," could have resolved the claim for correction. On the sufficiency of evidence for correction of names: Despite acknowledging the RTC's potential jurisdiction to grant the correction under Rule 108, the Court found that the petitioner failed to sufficiently establish the correct first and last names through competent evidence. The Court emphasized that the real name of a person is that given in the Civil Register, not the name by which they are known in the community or adopted. While petitioner presented his Elementary School Permanent Record and Professional Driver's License showing "Matiorico Ohomna," these were deemed insufficient. The Court highlighted the lack of stronger evidence such as the father's birth certificate, marriage certificate, or a government-issued identification card of the father. Furthermore, the Court noted significant discrepancies in the signatures of the informant (petitioner's mother) on both birth certificates, with no plausible explanation provided, casting doubt on the veracity of the second registration's entries.
Main Doctrine
A second registration of a birth that has already been validly registered within the reglementary period is void. The proper remedy for erroneous entries in a validly registered birth certificate is a petition for correction of entries under Rule 108 of the Rules of Court, not a cancellation and re-registration.