G.R. No. 239011 , June 17, 2019
Civil Service Commission vs. Pacol Disumimba Rasuman

FACTS

Respondent Pacol Disumimba Rasuman, a Senior Executive Assistant at the Bureau of Customs (BOC), filed a petition before the Regional Trial Court (RTC) for the correction of his date of birth from February 12, 1952 to February 12, 1956. The RTC granted the petition in a 2015 Decision, which became final and executory. The RTC directed the Local Civil Registrar to annotate the correction and ordered the BOC to correct his official records. Subsequently, Rasuman requested the Civil Service Commission (CSC) to correct his birthdate in his service records.
The CSC-NCR denied his request, noting inconsistencies; his school records indicated he attended elementary school starting in 1957, which would make him only one year old if born in 1956. The CSC Proper affirmed the denial, ruling it was not bound by the RTC Decision because the CSC was not impleaded as an indispensable party in the correction proceedings. The Court of Appeals (CA) reversed the CSC, directing it to comply with the RTC Decision, holding that the petition was an action in rem and publication of the notice bound all interested parties, including the CSC.

ISSUE

Whether the Court of Appeals erred in ruling that the Civil Service Commission is bound by the RTC Decision correcting the respondent’s date of birth despite not being impleaded in the proceedings.

RULING

The Supreme Court granted the petition and reversed the CA Decision. The Court held that the CSC is an indispensable party in a petition for correction of entries in a civil registry when such correction directly affects the civil status and employment records of a government employee. An indispensable party is one without whom no final determination can be had of an action, and whose interest would be directly affected by the judgment. The CSC, as the central personnel agency of the government that maintains the official service records of civil servants, has a direct and substantial interest in the correction of an employee’s birthdate, as it impacts retirement and other employment benefits.
The Court emphasized that while a petition for correction of entries is an action in rem, which generally binds the whole world upon compliance with publication requirements, this rule admits exceptions. The failure to implead an indispensable party is not cured by mere publication when the party’s identity and interest are known and ascertainable. Here, Rasuman knew that the correction would affect his employment records, yet he did not implead the CSC despite amending his petition to include the BOC. Consequently, the RTC Decision, while binding on the parties impleaded, produced no legal effect on the CSC. The CSC correctly exercised its authority to examine the evidence independently and deny the request based on discrepancies in the records. Therefore, the CSC’s denial of the request for correction was proper.