G.R. No. L-18606, December 26, 1963
Dy Kim Liong, petitioner-appellee, vs. Republic of the Philippines, oppositor-appellant.

FACTS

Dy Kim Liong filed a petition before the Court of First Instance of Manila seeking the correction of his son’s birth certificate. He requested that the child’s name be changed from Raynaldo Chan to Raynaldo Dy and that the father’s name be changed from Jose Chan to Dy Kim Liong. The government opposed the petition, moving to dismiss it on grounds of lack of cause of action and lack of jurisdiction. The trial court, instead of ruling on the motion, proceeded to trial and ultimately denied the main petition for correction.
However, in its dispositive portion, the trial court directed the Local Civil Registrar, invoking Sections 10, 11, and 12 of the Civil Register Law (Act No. 3753), to receive and attach to the child’s birth certificate a certified true copy of a Bureau of Immigration record showing petitioner’s name as Dy Kim Liong. The government moved for reconsideration of this specific directive, and upon its denial, elevated the case on appeal.

ISSUE

Whether the trial court, after dismissing the main petition for correction of entries in the birth certificate, could validly order the civil registrar to register and attach an immigration record to that certificate under the Civil Register Law.

RULING

The Supreme Court ruled in the negative and modified the trial court’s decision by deleting the directive for registration. The legal logic centers on a strict interpretation of the term “registrable” within Act No. 3753. The Court examined Sections 10, 11, and 12 of the law, which authorize the registration of court decrees concerning specific judicial matters such as adoption, change of name, naturalization, legitimation, and acknowledgment. The certified copy from the Bureau of Immigration is not a court decree resulting from such a proceeding; it is merely an administrative record.
The Court held that the document in question does not fall under the category of “registrable certificates and documents” as intended by Section 12(a) of the law. The term “registrable” is defined by reference to the judicial decrees enumerated in the preceding sections. To allow the registration of an extraneous document like an immigration record would expand the law’s scope beyond its clear textual limits and would effectively permit a circumvention of the proper judicial procedures required for a valid change of name or correction of entry. Since the main petition for correction was itself properly dismissed, granting the ancillary relief of attaching the immigration record was unauthorized. The trial court’s order was therefore a reversible error.