In the Philippines, the initial registration of a birth certificate holds significant legal weight. The Supreme Court, in this case, clarified that when a birth is registered within the legally prescribed period, that initial registration takes precedence. Even if subsequent registrations contain more accurate information, the original record stands, and any discrepancies must be corrected through the proper legal channels. This ruling underscores the importance of ensuring accuracy in the initial recording of vital statistics, as it forms the bedrock of a person’s legal identity.

Lost in a Name: When a Second Birth Certificate Clouds Identity

This case revolves around Matron M. Ohoma, also known as Matiorico M. Ohomna, who sought the cancellation of his first birth certificate due to discrepancies in his name. He claimed that his first name was erroneously recorded as “Matron” instead of “Matiorico” and his last name as “Ohoma” instead of “Ohomna.” Matron had a second birth certificate made with the correct entries and sought to retain this. The Regional Trial Court (RTC) initially favored Matron, ordering the cancellation of the first birth certificate. However, the Republic of the Philippines appealed, leading the Court of Appeals (CA) to reverse the RTC’s decision, emphasizing the validity of the first registration and directing Matron to seek correction of entries under Rule 108 of the Rules of Court. This brought the case before the Supreme Court, where the core issue was whether the CA erred in overturning the RTC’s decision.

The Supreme Court affirmed the Court of Appeals’ decision, emphasizing the importance of the initial birth registration. Under Philippine law, specifically Office of the Civil Registrar-General Administrative Order No. 1, Series of 1983, a birth must be registered within 30 days of its occurrence. In Matron’s case, his birth was initially registered on June 13, 1986, falling within this timeframe. The court reasoned that because a valid initial registration existed, the subsequent registration was invalid and should be cancelled. The pursuit of the individual to cancel the first birth certificate and to retain the second birth certificate was due to erroneous entries. However, the Supreme Court declared that it is the second birth certificate that should be cancelled.

The court also addressed the proper procedure for correcting errors in civil registry documents. Citing Article 412 of the Civil Code, the Supreme Court reiterated that no entry in a civil register can be changed or corrected without a judicial order. Rule 108 of the Rules of Court outlines the judicial process for such corrections or cancellations. The Court emphasized that the action filed by the petitioner before the RTC seeks to correct a supposedly misspelled name, and thus, properly falls under Rule 108. Correcting an entry means, to make or set aright; to remove the faults or error from.

However, the Supreme Court found that the petitioner failed to provide sufficient evidence to prove that his father’s last name was Ohomna and not Ohoma. The court stated that it should be presented through competent evidence such as the latter’s birth certificate, the certificate of his marriage to the petitioner’s mother, or a government-issued identification card. The real name of a person is that given to him in the Civil Register, not the name by which he was baptized in his Church or by which he was known in the community, or which he has adopted. While the first name may be freely selected by the parents for the child, the last name to which the child is entitled is fixed by law.

“Article 412. No entry in a civil register shall be changed or corrected, without a judicial order.”

The Court also pointed out inconsistencies in the mother’s signatures on the two birth certificates, raising further doubts about the accuracy and validity of the second registration. The mother signed as Antonia Ohoma on the first birth certificate and Antonia Ohomna on the second birth certificate. Ultimately, the Supreme Court denied the petition, setting aside the Court of Appeals’ decision and ordering the cancellation of Matron M. Ohoma’s second Certificate of Live Birth. This decision reinforces the legal principle that the initial birth registration is paramount and that corrections must be pursued through the proper legal channels with sufficient evidentiary support.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals erred in annulling the RTC ruling that ordered the cancellation of the petitioner’s first birth certificate. This involved determining which birth certificate should be considered valid when there are two registrations with conflicting information.
Why did the Supreme Court favor the first birth certificate?	The Supreme Court favored the first birth certificate because it was the initial registration, made within 30 days of the petitioner’s birth as required by law. The Court emphasized that the initial registration takes precedence.
What is the proper procedure for correcting errors in a birth certificate?	The proper procedure is to file a petition for correction of entries under Rule 108 of the Rules of Court. This involves a judicial process to ensure that any changes to the civil registry are legally sound.
What kind of evidence is needed to correct a name on a birth certificate?	Competent evidence is required, such as the birth certificates of parents, marriage certificates, or government-issued identification cards. The court requires solid proof to justify any alterations to the civil registry.
What happens if the initial birth registration contains errors?	Even if the initial registration contains errors, it remains the primary record. The proper course of action is to file a petition for correction, rather than obtaining a second birth certificate.
Can a second birth certificate be considered valid if the first one exists?	No, a second birth certificate is generally not considered valid if the first one exists and was registered within the prescribed period. The initial registration holds legal precedence.
What role does the Local Civil Registrar play in these cases?	The Local Civil Registrar is responsible for maintaining accurate records of births, deaths, and marriages. They are tasked with implementing court orders for corrections or cancellations of entries in the civil registry.
What is the significance of Article 412 of the Civil Code in this case?	Article 412 underscores that no entry in a civil register can be changed or corrected without a judicial order. This provision highlights the importance of legal processes in maintaining the integrity of civil records.

This case underscores the importance of accuracy in initial birth registrations and the legal pathways available for correcting errors. It also highlights the need for sufficient evidence to support any claims for correction. The decision serves as a reminder that while mistakes can be rectified, the integrity of civil records is paramount and must be upheld through proper legal procedures.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Matron M. Ohoma (Matiorico M. Ohomna) v. Office of the Municipal Local Civil Registrar of Aguinaldo, Ifugao and Republic of the Philippines, G.R. No. 239584, June 17, 2019