SECOND DIVISION
|
REPUBLIC OF THE Petitioner, - versus - MERLYN MERCADERA through her
Attorney-in-Fact, EVELYN M. OGA, Respondent. |
|
G.R. No. 186027 Present: CARPIO, J.,
Chairperson, NACHURA, PERALTA, ABAD, and MENDOZA, JJ. Promulgated: December
8, 2010 |
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D E C I S I O N
MENDOZA,
J.:
This petition for review on certiorari assails the
The
Factual and Procedural Antecedents
On June 6, 2005, Merlyn Mercadera (Mercadera),
represented by her sister and duly constituted Attorney-in-Fact, Evelyn M. Oga (Oga),
sought the correction of her given name as it appeared in her Certificate of
Live Birth - from Marilyn L. Mercadera to Merlyn L. Mercadera
before the Office of the Local Civil Registrar of Dipolog City pursuant to Republic
Act No. 9048 (R.A. No. 9048).[2]
Under R.A. No. 9048, the city or municipal civil registrar or
consul general, as the case may be, is now authorized to effect the change of first
name or nickname and the correction of clerical or typographical errors in
civil registry entries. “Under said law,
jurisdiction over applications for change of first name is now primarily lodged
with administrative officers. The law
now excludes the change of first name from the coverage of Rules 103 until and
unless an administrative petition for change of name is first filed and
subsequently denied”[3]
and removes “correction or changing of clerical errors in entries of the civil
register from the ambit of Rule 108.” Hence,
what is left for the scope of operation of the rules are substantial changes
and corrections in entries of the civil register.[4]
The Office of the Local Civil Registrar of Dipolog City,
however, refused to effect the correction unless a court order was obtained “because
the Civil Registrar therein is not yet equipped with a permanent appointment before
he can validly act on petitions for corrections filed before their office as
mandated by Republic Act 9048.”[5]
Mercadera was then constrained to file a Petition For
Correction of Some Entries as Appearing in the Certificate of Live Birth
under Rule 108 before the
SEC. 2. Entries subject to cancellation or correction.
– Upon good and valid grounds,
the following entries in the civil register may be cancelled or corrected: (a)
births; (b) marriages; (c) deaths; (d) legal separations; (e) judgments of
annulments of marriage; (f) judgments declaring marriages void from the
beginning; (g) legitimations; (h) adoptions; (i) acknowledgments of natural
children; (j) naturalization; (k) election, loss or recovery of citizenship;
(l) civil interdiction; (m) judicial determination of filiation; (n) voluntary
emancipation of a minor; and (o) changes of name.
[Underscoring supplied]
Upon receipt of the petition for correction of entry, the RTC
issued an order, dated
Finding the petition sufficient in form
and substance, notice is hereby given that the hearing of said petition is set
on JULY 26, 2005 at 8:30 o’clock in the morning, at the Session Hall of Branch
8, this Court, Bulwagan ng Katarungan, Dipolog City, on which date, time and
place, anyone appearing to contest the petition shall state in writing his
grounds there[for], serving a copy thereof to the petitioner and likewise file
copies with this Court on or before the said date of hearing.
Let this order be published at the
expense of petitioner once a week for three (3) consecutive weeks in a
newspaper edited and published in Dipolog City and of general circulation
therein, the City of Dapitan and the province of Zamboanga del Norte, and
copies hereof be furnished to the Office of the Solicitor General of (sic) 134
Amorsolo St., Legaspi Village, Makati, Metro Manila, the City Civil Registrar
of Dipolog, and posted on the bulletin boards of the City Hall of Dipolog, the
Provincial Capitol Building, and of this Court.
IT IS SO ORDERED.
The Office of the Solicitor General (OSG) entered its
appearance for the Republic of the
On
The following facts were gathered from documentary evidence
and the oral testimony of Oga, as reported by the lower court:
Petitioner Merlyn M. Mercadera was born
on
On
In her elementary diploma issued by the
Paaralang Sentral ng Estaka, Dipolog City; her high school diploma issued by
the Zamboanga del Norte School of Arts and Trades, Dipolog City; and college
diploma issued by the Silliman University, Dumaguete City, where she earned the
degree of Bachelor of Secondary Education, uniformly show her name as Merlyn L.
Mercadera (Exhibits “E”, “F”, and “G”).
Presently, she is working in U.P.
Mindanao, Buhangin,
When she secured an authenticated copy of her certificate of live birth from the National Statistics Office, she discovered that her given name as registered is Marilyn and not Merlyn; hence, this petition.
In its
WHEREFORE, the petition is GRANTED.
Accordingly, the Office of the City Civil Registrar of Dipolog City is hereby
directed to correct the given name of petitioner appearing in her certificate
of live birth, from Marilyn Lacquiao Mercadera to MERLYN Lacquiao Mercadera.
In a four-page decision, the RTC ruled
that the documentary evidence presented by Mercadera sufficiently supported the
circumstances alleged in her petition. Considering that she had used “Merlyn”
as her given name since childhood until she discovered the discrepancy in her
Certificate of Live Birth, the RTC was convinced that the correction was
justified.
The OSG timely interposed an appeal praying for the reversal and setting
aside of the RTC decision. It mainly
anchored its appeal on the availment of Mercadera of the remedy and procedure
under Rule 108. In its Brief[9]
filed with the CA, the OSG argued that the lower court erred (1) in granting
the prayer for change of name in a petition for correction of entries; and (2)
in admitting the photocopies of documentary evidence and hearsay testimony of
Oga.
For the OSG, the correction in the spelling of Mercadera’s given name might
seem innocuous enough to grant but “it is in truth a material correction as it
would modify or increase substantive rights.”[10] What the lower court actually allowed was a
change of Mercadera’s given name, which would have been proper had she filed a
petition under Rule 103 and proved any of the grounds therefor. The lower court, “may not substitute one for
the other for purposes of expediency.”[11] Further, because Mercadera failed to invoke a
specific ground recognized by the Rules, the lower court’s order in effect
allowed the change of one’s name in the civil registry without basis.
The CA was not persuaded.
In its
Appellant’s
insistence that the petition should have been filed under Rule 103 and not Rule
108 of the Rules of Court is off the mark. This Court does not entertain any
doubt that the petition before the trial court was one for the correction on an entry in petitioner’s
Certificate of Live Birth and not one in which she sought to change her name. In Co v. Civil Register of Manila,
G.R. No. 138496,
That
appellee sought to correct an entry and not to change her name is patent to the
Court from the allegations in her petition, specifically, paragraphs 7 and 8
thereof—
x x x x
Anent the RTC’s error in admitting the photocopies of Mercadera’s
documentary evidence and in vesting probative value to Oga’s testimony, the CA
cited the well-established rule that “evidence not objected to may be admitted
and may be validly considered by the court in arriving at its judgment.”[13]
On
I
THE COURT OF APPEALS ERRED ON A QUESTION OF
LAW IN GRANTING THE CHANGE IN RESPONDENT’S NAME UNDER RULE 103.
II
THE COURT OF APPEALS ERRED ON A QUESTION OF
LAW IN CONSIDERING SECONDARY EVIDENCE.
Rule 103 procedurally governs judicial petitions for change
of given name or surname, or both, pursuant to Article 376 of the Civil Code.[16] This rule provides the procedure for an
independent special proceeding in court to establish
the status of a person involving his relations with others, that is, his legal
position in, or with regard to, the rest of the community.[17] In petitions for
change of name, a person avails of a remedy to alter the “designation by which
he is known and called in the community in which he lives and is best known.”[18] When granted, a person’s
identity and interactions
are affected as he bears a new “label or appellation for the convenience of the
world at large in addressing him, or in speaking of, or dealing with him.”[19] Judicial permission for a
change of name aims to prevent fraud and to ensure a record of the change by
virtue of a court decree.
The proceeding under Rule 103 is also an action in rem which requires publication of the
order issued by the court to afford the State and all other interested parties
to oppose the petition. When complied
with, the decision binds not only the parties impleaded but the whole
world. As notice to all, publication
serves to indefinitely bar all who might make an objection. “It is the publication of such notice that
brings in the whole world as a party in the case and vests the court with
jurisdiction to hear and decide it.”[20]
Essentially, a change of name does not define or effect a
change of one’s existing family relations or in the rights and duties flowing
therefrom. It does not alter one’s legal capacity or civil status.[21] However, “there
could be instances where the change applied for may be open to objection by
parties who already bear the surname desired by the applicant, not because he
would thereby acquire certain family ties with them but because the existence
of such ties might be erroneously impressed on the public mind.”[22] Hence, in requests for a change of name, “what is
involved is not a mere matter of allowance or disallowance of the request, but
a judicious evaluation of the sufficiency and propriety of the justifications
advanced x x x mindful of the
consequent results in the event of its grant x x x.”[23]
Rule 108, on the other hand, implements judicial proceedings
for the correction or cancellation of entries in the civil registry pursuant to
Article 412 of the Civil Code.[24] Entries in the civil register refer to “acts,
events and judicial decrees concerning the civil status of persons,”[25]
also as enumerated in Article 408 of the same law.[26] Before, only mistakes or errors of a harmless
and innocuous nature in the entries in the civil registry may be corrected
under Rule 108 and substantial errors affecting the
civil status, citizenship or nationality of a party are beyond the ambit of the
rule. In the abandoned case of Chua Wee v.
Republic,[27]
this Court declared that,
x x x if Rule
108 were to be extended beyond innocuous or harmless changes or corrections of
errors which are visible to the eye or obvious to the understanding, so as to
comprehend substantial and controversial alterations concerning citizenship,
legitimacy of paternity or filiation, or legitimacy of marriage, said Rule 108
would thereby become unconstitutional for it would be increasing or modifying
substantive rights, which changes are not authorized under Article 412 of the
new Civil Code."
In the latter case of Wong v. Republic,[28] however, Justice Vicente Abad Santos, in a separate concurrence, opined that Article 412, which Rule 108 implements, contemplates all kinds of issues and all types of procedures because “the provision does not say that it applies only to non-controversial issues and that the procedure to be used is summary in nature.” In Republic v. Judge De la Cruz,[29] the dissenting opinion penned by Justice Pacifico De Castro echoed the same view:
It is not accurate to say that Rule 108
would be rendered unconstitutional if it would allow the correction of more
than mere harmless clerical error, as it would thereby increase or modify
substantive rights which the Constitution expressly forbids because Article 412
of the Civil Code, the substantive law sought to be implemented by Rule 108,
allows only the correction of innocuous clerical errors not those affecting the
status of persons. As was stressed in the dissent on the aforesaid Wong Case,
Article 412 does not limit in its express terms nor by mere implication, the
correction authorized by it to that of mere clerical errors. x x x it would be
reasonable and justified to rule that Article 412 contemplates of correction of
erroneous entry of whatever nature, procedural safeguards having only to be
provided for, as was the manifest purpose of Rule 108.
x x x proceedings for the correction of
erroneous entry should not be considered as establishing one's status in a
legal manner conclusively beyond dispute or controversion, x x x the books
making up the civil register and all documents relating thereto x x x shall be prima facie evidence of the
facts therein contained. Hence, the status as corrected would not have a
superior quality for evidentiary purpose. Moreover, the correction should not
imply a change of status but a mere rectification of error to make the matter
corrected speak for the truth. x x x
Finally
in Republic v. Valencia,[30] the
above stated views were adopted by this Court insofar as even substantial
errors or matters in a civil registry may be corrected and the true facts
established, provided the parties aggrieved avail themselves of the appropriate
adversary proceeding. “If the purpose of the petition is merely to correct the
clerical errors which are visible to the eye or obvious to the understanding, the court may, under a
summary procedure, issue an order for the correction of a mistake. However, as repeatedly construed, changes which may affect the civil status
from legitimate to illegitimate, as well as sex, are substantial and
controversial alterations which
can only be allowed after appropriate adversary proceedings depending upon the nature
of the issues involved. Changes which affect the civil status or
citizenship of a party are substantial in character and should be threshed
out in a proper action depending upon the nature of the issues in controversy,
and wherein all the parties who may be affected by the entries are notified or
represented and evidence is submitted to prove the allegations of the
complaint, and proof to the contrary admitted x x x.”[31] “Where
such a change is ordered, the Court will not be establishing a substantive
right but only correcting or rectifying an erroneous entry in the civil
registry as authorized by law. In short,
Rule 108 of the Rules of Court provides only the procedure or mechanism for the
proper enforcement of the substantive law embodied in Article 412 of the Civil
Code and so does not violate the Constitution.”[32]
In the case at bench, the OSG posits that the conversion from
“MARILYN” to “MERLYN” is not a correction of an innocuous error but a material
correction tantamount to a change of name which entails a modification or
increase in substantive rights. For the OSG, this is a substantial error that
requires compliance with the procedure under Rule 103, and not Rule 108.
It appears from these arguments that there is, to some
extent, confusion over the scope and application of Rules 103 and Rule 108. Where a “change of name” will necessarily be
reflected by the corresponding correction in an entry, as in this case, the
functions of both rules are often muddled.
While there is no clear-cut rule to categorize petitions under either
rule, this Court is of the opinion that a resort to the basic distinctions
between the two rules with respect to alterations in a person’s registered name
can effectively clear the seeming perplexity of the issue. Further, a careful evaluation of
circumstances alleged in the petition itself will serve as a constructive guide
to determine the propriety of the relief prayed for.
The “change
of name” contemplated under Article 376 and Rule 103 must not be
confused with Article 412 and Rule 108. A change of one’s name under Rule 103 can be granted, only
on grounds provided by law. In order to
justify a request for change of name, there must be a proper and compelling
reason for the change and proof that the person requesting will be prejudiced
by the use of his official name. To
assess the sufficiency of the grounds invoked therefor, there must be
adversarial proceedings.[33]
In petitions for correction, only clerical, spelling,
typographical and other innocuous errors in the civil registry may be
raised. Considering that the enumeration
in Section 2,
Rule 108[34] also
includes “changes of name,” the correction of a patently misspelled name is covered by Rule 108. Suffice it to say, not all alterations
allowed in one’s name are confined under Rule 103. Corrections for clerical
errors may be set right under Rule 108.
This rule in “names,” however, does not operate to entirely
limit Rule 108 to the correction of clerical errors in civil registry entries
by way of a summary proceeding. As explained above, Republic v. Valencia is the authority for allowing substantial errors in other entries like citizenship,
civil status, and paternity, to be corrected using Rule 108 provided there is
an adversary proceeding. “After all, the role of the Court under Rule 108 is to ascertain
the truths about the facts recorded therein.”[35]
A serious scrutiny of this petition reveals a glaring lack of
support to the OSG’s assumption that Mercadera intended to change her name
under Rule 103. All that the petition
propounded are swift arguments on the alleged procedural flaws of Mercadera’s
petition before the RTC. In the same
vein, no concrete contention was brought up to convince this Court that the
dangers sought to be prevented by the adversarial proceedings prescribed in
Rule 103 are attendant in this case. Instead, the RTC found the documents
presented by Mercadera to have satisfactorily shown that she had been known as
MERLYN ever since, discounting the possibility that confusion, or a
modification of substantive rights might arise.
Truth be told, not a single oppositor appeared to contest the petition
despite full compliance with the publication requirement.
Thus, the petition filed by Mercadera before the RTC correctly
falls under Rule 108 as it simply sought a correction of a misspelled given
name. To correct simply means “to make
or set aright; to remove the faults or error from.” To change means “to replace
something with something else of the same kind or with something that serves as
a substitute.”[36] From the
allegations in her petition, Mercadera clearly prayed for the lower
court “to remove the faults or error” from her registered given name “MARILYN,”
and “to make or set aright” the same to conform to the one she grew up to,
“MERLYN.” It does not take a complex
assessment of said petition to learn of its intention to simply correct the clerical
error in spelling. Mercadera even attempted to avail of the remedy allowed
by R.A. No. 9048 but she unfortunately failed to enjoy the expediency which the
law provides and was constrained to take court action to obtain relief. Thus, the petition was clear in stating:
7. That as
such, there is a need to correct
her given name as appearing in
her Certificate of Live Birth from MARILYN to MERLYN to conform to her true and correct given
name that she had been using
and had been known within the community x x x.
8. That herein petitioner went to the Office of the Local Civil Registrar of Dipolog City and requested them to effect such correction in her Certificate of Live Birth, however, the Local Civil Registrar of Dipolog City will not effect such correction unless an order is obtained by herein petitioner from this Honorable Court because the Local Civil Registrar therein is not yet equipped with permanent appointment before he can validly act on petitions for corrections filed before their office as mandated by Republic Act 9048, hence the filing of this petition. [Emphases supplied]
Indeed, there are decided
cases involving mistakes similar to Mercadera’s case which recognize the same
a harmless error. In Yu v. Republic[37] it
was held that “to change ‘Sincio’ to ‘Sencio’ which merely involves the
substitution of the first vowel ‘i’ in the first name into the vowel ‘e’
amounts merely to the righting of a clerical error.” In Labayo-Rowe v. Republic,[38] it was held that the change of petitioner’s
name from “Beatriz Labayo/Beatriz Labayu” to “Emperatriz Labayo” was a mere
innocuous alteration wherein a summary proceeding was appropriate. In Republic v. Court of Appeals, Jaime B.
Caranto and Zenaida P. Caranto, the correction
involved the substitution of the letters “ch” for the letter “d,” so that what
appears as “Midael” as given name would read “Michael.” In the latter case, this Court, with the
agreement of the Solicitor General, ruled that the error was plainly clerical,
such that, “changing the name of the child from ‘Midael C. Mazon’ to ‘Michael
C. Mazon’ cannot possibly cause any confusion, because both names can be read
and pronounced with the same rhyme (tugma)
and tone (tono, tunog, himig).”[39]
In this case, the use of the letter “a” for
the letter “e,” and the deletion of the letter “i,” so that what appears as
“Marilyn” would read as “Merlyn” is patently a rectification of a name that is
clearly misspelled. The similarity
between “Marilyn” and “Merlyn” may well be the object of a mix- up that
blemished Mercadera’s Certificate of Live Birth until her adulthood, thus, her interest
to correct the same.
The CA did not allow Mercadera the
change of her name. What it did allow
was the correction of her misspelled given name which she had been using ever
since she could remember.
It is
worthy to note that the OSG’s reliance on Republic vs.
Hernandez[40] is flawed. In that case, this Court
said that “a change in a given name is a substantial matter” and that it “cannot be granted by means of any other proceeding that
would in effect render it a mere incident or an offshoot of another special
proceeding.” While this Court
stands true to the ruling in Hernandez, the
said pronouncement therein was stated in a different tenor and, thus,
inapplicable to this case. Hernandez was decided against an
entirely different factual milieu. There was a petition for adoption that must
not have led to a corresponding change in the adoptee’s given name because “it would be procedurally
erroneous to employ a petition for adoption to effect a change of name in the
absence of a corresponding petition for the latter relief at law.” In the present case, the issue is the
applicability of either Rule 103 or Rule 108 and the relief sought by Mercadera
can in fact be granted under the latter.
This Court finds no attempt on the part of Mercadera to render the
requirements under Rule 103 illusory as in Hernandez.
Besides, granting that Rule 103 applies to this case and that
compliance with the procedural requirements under Rule 108 falls short of what
is mandated, it still cannot be denied that Mercadera complied with the
requirement for an adversarial proceeding before the lower court. The publication and posting of the notice of
hearing in a newspaper of general circulation and the notices sent to the OSG
and the Local Civil Registry are sufficient indicia
of an adverse proceeding. The fact that
no one opposed the petition, including the OSG, did not deprive the court of
its jurisdiction to hear the same and did not make the proceeding less
adversarial in nature. Considering that the OSG did not oppose the
petition and the motion to present its evidence ex parte when it had the opportunity to
do so, it cannot now complain that the proceedings in the lower court were
procedurally defective. Indeed, it has
become unnecessary to further discuss the reasons why the CA correctly affirmed
the findings of the lower court especially in admitting and according probative
value to the evidence presented by Mercadera.
WHEREFORE, the
SO ORDERED.
JOSE
CATRAL
Associate Justice
WE CONCUR:
ANTONIO T. CARPIO
Associate Justice
Chairperson
ANTONIO EDUARDO B.
NACHURA DIOSDADO M. PERALTA
Associate Justice
Associate Justice
ROBERTO A. ABAD
Associate Justice
A T T E S T A T I O N
I attest that the conclusions in the above Decision had
been reached in consultation before the case was assigned to the writer of the
opinion of the Court’s Division.
ANTONIO T. CARPIO
Associate Justice
Chairperson,
Second Division
C E R T I F I CA T I O N
Pursuant to Section 13, Article VIII of the Constitution
and the Division Chairperson’s Attestation, I certify that the conclusions in
the above Decision had been reached in consultation before the case was
assigned to the writer of the opinion of the Court’s Division.
RENATO C. CORONA
Chief
Justice
[1] Rollo, pp. 19-25. Penned by Associate Justice Romulo V. Borja and concurred in by Associate Justices Mario V. Lopez and Elihu A. Ybanez, of the Twenty-first Division, Cagayan de Oro City.
[2] An Act Authorizing the City or Municipal Civil Registrar or the Consul General to Correct a Clerical or Typographical Error in an Entry and/or Change of First Name or Nickname in the Civil Register without Need of a Judicial Order, Amending for this Purpose Articles 376 and 412 of the Civil Code of the Philippines.
[3] Rommel Jacinto Dantes Silverio v. Republic of the
[4] Milagros M. Barco, as the Natural Guardian and Guardian Ad Litem of Mary Joy Ann Gustillo v. Court of Appeals, 465 Phil. 39, 61 (2004).
[5] Paragraph 8, Petition for Correction of Some Entries as Appearing in the Certificate of Live Birth of Merlyn Mercadera; Records, p. 2.
[6] Records, p. 33.
[7] Exhibit “A”-Affidavit of Publication; Exhibit “A-1” to “A-3”-newspaper clippings; Exhibit “B”-Special Power of Attorney; Exhibit “C”-Birth Certificate; Exhibit “D”-Certificate of Baptism; Exhibit “E”-Elementary School Certificate; Exhibit “F”-High School Diploma; Exhibit “G”-College Diploma; Exhibit “H”-GSIS Certificate of Membership; and Exhibit “I”-Community Tax Certificate.
[8] Records, pp. 34-37.
[9] CA rollo, Brief for the Appellant, pp. 13-22.
[10]
[11]
[12] CA rollo, pp. 48-54.
[13] Heirs of
Marcelino Doronio v. Heirs of Fortunato Doronio, G.R. No. 186027, December
27, 2007, 541 SCRA 479.
[14] Rollo, pp. 33-44.
[15]
[16] “No person can change his name or surname without judicial authority.”
[17] Republic v. Court of Appeals,
G.R. No. 97906,
[18] In the Matter
of the Adoption of Stephanie Nathy Astorga Garcia, 494 Phil. 515 (2005).
[19] Del Prado v. Republic, 126 Phil. 1 (1967).
[20] Milagros M.
Barco, as the Natural Guardian and Guardian Ad Litem of Mary Joy Ann Gustillo
v. Court of Appeals, supra note 4 at 57, citing Republic
v. Honorable Judge of Branch III, CFI of Cebu City, 217 Phil 442 (1984).
[21] Supra note 17.
[22] In the matter
of the petition to change name of Ong Huan Tin to Teresita Tan Ong Huan Tin v.
Republic of the Philippines, 126 Phil. 201 (1967).
[23] In re: Petition
for Change of Name and/or Correction/Cancellation of Entry in Civil Registry of
Julian Lin Carulasan Wang v.
[24] “No entry in a civil register shall be changed or corrected, without a judicial order.”
[25] Article 407, Civil Code.
[26] Article 408. The following shall be entered in the
civil register:(1) Births; (2) marriages; (3) deaths; (4) legal separations;
(5) annulments of marriage; (6) judgments declaring marriages void from the
beginning; (7) legitimations; (8) adoptions; (9) acknowledgments of natural
children; (10) naturalization; (11) loss, or (12) recovery of citizenship; (13)
civil interdiction; (14) judicial determination of filiation; (15) voluntary
emancipation of a minor; and (16)
changes of name. (Emphasis supplied)
[27] 148 Phil. 422 (1971).
[28] 201 Phil. 69 (1982).
[29] 203 Phil. 402 (1982).
[30] 225 Phil. 408 (1986).
[31] Lee v. Court of
Appeals, 419 Phil. 392 (2001), citing Labayo-Rowe
v. Republic of the Philippines, 250 Phil. 300 (1988).
[32] Antonio Chiao
Ben Lim v. Hon. Mariano A. Zosa and the Local Civil Registrar of the
City of
[33] "One having opposing parties, contested, as
distinguished from an ex parte application, one [in] which the party
seeking relief has given legal warning to the other party, and afforded the
latter an opportunity to contest it. xxx," cited in Republic of the
Philippines v. Labrador, 364 Phil. 934 (1999).
[34] Section 2, Rule 108 x x x (a) births; (b)
marriages; (c) deaths; (d) legal separations; (e) judgments of annulments of
marriage; (f) judgments declaring marriages void from the beginning; (g)
legitimations; (h) adoptions; (i) acknowledgments of natural children; (j)
naturalization; (k) election, loss or recovery of citizenship; (l) civil
interdiction; (m) judicial determination of filiation; (n) voluntary
emancipation of a minor; and (o) changes of name.
[35] Hubert Tan Co and Arlene Tan
Co v. The Civil Register of
[36]
[37] 129 Phil. 248 (1967).
[38] Emperatriz
Labayo-Rowe v. Republic of the
[39] 325 Phil. 361 (1996).
[40] 323 Phil. 606 (1996).