G.R. No. 203371, June 30, 2020
Republic of the Philippines, Petitioner, vs. Charlie Mintas Felix, a.k.a. Shirley Mintas Felix, Respondent.

FACTS

Respondent Charlie Mintas Felix, also known as Shirley Mintas Felix, filed a Petition for Correction of Entries with the Regional Trial Court (RTC) of La Trinidad, Benguet. He alleged that his birth was erroneously registered with the Local Civil Registrar (LCR) of Itogon, Benguet, with the following mistakes: his first name as “Shirley” instead of “Charlie,” his gender as “female” instead of “male,” and his father’s surname as “Filex” instead of “Felix.” He possessed a second birth certificate from the LCR of Carranglan, Nueva Ecija, which carried the correct entries, and he used this in his official transactions. However, the National Statistics Office (NSO) officially released only the erroneous Itogon certificate. He prayed for the correction of the Itogon birth certificate and the cancellation of the Carranglan birth certificate. The Republic of the Philippines, through the Office of the Solicitor General, opposed, arguing that the RTC-La Trinidad lacked jurisdiction to order the LCR-Carranglan, Nueva Ecija, to cancel the second certificate. The trial court granted the petition, ordering the correction of the Itogon record and the cancellation of the Carranglan record. The Court of Appeals affirmed this decision. The Republic appealed, reiterating its jurisdictional challenge and further raising the issue of whether Republic Act No. 9048, as amended by Republic Act No. 10172, divested the RTCs of jurisdiction over such petitions.

ISSUE

1. Whether the Court of Appeals committed reversible error in upholding the trial court’s jurisdiction to order the LCR-Carranglan, Nueva Ecija, to cancel the respondent’s second birth certificate.
2. Whether Republic Act No. 9048, as amended by Republic Act No. 10172, divested the regional trial courts of jurisdiction over petitions for correction of entries in the civil registry.

RULING

The Supreme Court dismissed the petition and affirmed the Court of Appeals’ decision.
1. On the first issue, the Court ruled that the Court of Appeals correctly upheld the trial court’s ancillary jurisdiction to order the cancellation of the second birth certificate. Jurisdiction over the main case (correction of entries in the Itogon certificate) embraces all incidental matters arising therefrom. The cancellation of the Carranglan certificate was a necessary consequence of the main action for correction. Citing the doctrine of ancillary jurisdiction, the Court held that a court may decide matters incidental to the main action to effectuate its authority, even if such matters, as original causes of action, would not be within its cognizance. Requiring two separate petitions would violate the rule against multiplicity of suits. Furthermore, a petition for correction is an action in rem; the decision binds the whole world, including the LCR-Carranglan, which was duly notified.
2. On the second issue, the Court ruled that Republic Act No. 9048, as amended by Republic Act No. 10172, did not divest the regional trial courts of their jurisdiction over petitions for correction of entries. Section 19 of Batas Pambansa Blg. 129 grants RTCs exclusive original jurisdiction over actions not capable of pecuniary estimation, which includes petitions for correction under Rule 108 of the Rules of Court. The enactment of the administrative remedy under RA 9048, as amended, created an alternative, not an exclusive, procedure. The failure to exhaust this administrative remedy does not affect the court’s jurisdiction; it merely deprives the complainant of a cause of action, which is a waivable ground for a motion to dismiss. Therefore, RTCs retain jurisdiction.