G.R. No. 170645 ; July 9, 2010
NIEVES ESTARES BALDOS, substituted by FRANCISCO BALDOS and MARTIN BALDOS, Petitioners, vs. COURT OF APPEALS and REYNALDO PILLAZAR a.k.a. REYNALDO ESTARES BALDOS, Respondents.

FACTS

Respondent Reynaldo Pillazar, alias Reynaldo Baldos, was born on October 30, 1948. His birth was registered late on February 11, 1985, with a certificate of live birth indicating Nieves Baldos and Bartolome Baldos as his parents, and with Nieves herself as the informant. On March 8, 1995, Nieves Baldos filed a complaint in the Regional Trial Court (RTC) of Olongapo City seeking the cancellation of this late registration, claiming Reynaldo was not her son. The RTC dismissed the petition, finding the documentary evidence and declarations of disinterested neighbors overwhelmingly supported Reynaldo’s filiation, while Nieves offered only her bare denial.
Nieves appealed to the Court of Appeals (CA), arguing the late registration violated Presidential Decree No. 651. The CA affirmed the RTC, holding that P.D. No. 651 did not prohibit the late registration of births occurring before January 1, 1974. Nieves died during the pendency of the case, and her brothers-in-law, Francisco and Martin Baldos, were substituted as petitioners. They elevated the case to the Supreme Court.

ISSUE

The sole issue is whether the late registration of Reynaldo’s birth is valid.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision, upholding the validity of the late registration. The Court clarified that P.D. No. 651, which mandates registration for births from January 1, 1974, onward, does not prohibit or invalidate the late registration of births occurring before that date. The law’s purpose is to encourage registration, not to restrict it for earlier births. The Court emphasized that the governing law for such delayed registration is the Civil Registry Law ( Act No. 3753 ) and its implementing rules, which provide a specific administrative procedure requiring supporting documents and affidavits to ensure authenticity.
Applying these principles, the Court found that Reynaldo’s late registration complied with the requisite procedure. His certificate of live birth is a public document entitled to the presumption of regularity. The burden to overcome this presumption rested on the petitioners, who failed to present clear and convincing evidence of falsity. Nieves’ mere denial, unsupported by corroborative evidence, was insufficient to contradict the documentary proof and testimonies affirming Reynaldo’s filiation. Therefore, the trial and appellate courts correctly refused to cancel the registration.