GR L 17639; (May, 1964) (Digest)
G.R. No. L-17639; May 29, 1964
CESAR PABLO OBESO BEDUYA, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, respondent-appellant.
FACTS
Petitioner Cesar Pablo Obeso Beduya filed a petition under Article 412 of the Civil Code seeking the correction of his marriage contract recorded in the Civil Registrar of Carcar, Cebu, the local Roman Catholic Church, and the Bureau of Public Libraries. The petition sought to delete the names “Sabas Obeso” and “Juana Bertoldo” as his parents and substitute them with “Marcial Beduya” and “Maxima Obeso,” and to change his name from “Pablo Obeso” to “Cesar Pablo Obeso Beduya.” At trial, petitioner testified that Sabas and Juana were his maternal grandparents, not his parents. He claimed his true parents were Marcial and Maxima, who had him out of wedlock, later married, and left him with his grandparents. He adopted his full name at age ten. The Court of First Instance of Cebu granted the petition.
ISSUE
Whether the corrections sought by the petitioner, which involve changes to his parentage and name, can be effected through a summary proceeding under Article 412 of the Civil Code.
RULING
No. The Supreme Court reversed the lower court’s decision and dismissed the petition. The legal logic is anchored on the limited scope of corrections allowable under Article 412 of the Civil Code. The Court, citing precedents like Ty Kong Tin v. Republic and Black v. Republic, held that Article 412 permits only the correction of clerical errors—those that are visible, obvious, and harmless, such as misspellings or innocuous misstatements. The changes sought by the petitioner are substantial, not clerical. Altering the identities of one’s parents directly affects filiation and civil status, which encompasses a person’s legal capacities and incapacities within the family structure. Such a change carries significant implications for rights and obligations and cannot be adjudicated in a summary proceeding where the affected parties—the individuals listed as parents and the alleged true parents—were not made parties to the case or given an opportunity to be heard. The proceeding was therefore improper for effecting the desired substantial alterations. The Court found it unnecessary to rule on the ancillary issue of whether the lower court had jurisdiction to order corrections in the church and library records.