Republic v. Court of Appeals

G.R. No. 103695 (March 15, 1996)

Facts:

This case involves a petition for the adoption of Midael C. Mazon, a minor who was fifteen years old at the time of the petition. The private respondents, spouses Jaime B. Caranto and Zenaida P. Caranto, had been caring for Midael since he was seven years old. They married on January 19, 1986, and Midael had been living with them since then. The private respondents sought to adopt Midael and requested that his first name be corrected from "Midael" to "Michael," arguing that the latter was the name they intended to use.

The Regional Trial Court (RTC) of Cavite City set a hearing for the adoption petition and provided notice through publication and service to relevant government offices. The Solicitor General opposed the name correction, asserting that the petition was primarily for adoption and not for correcting a civil registry entry under Rule 108 of the Rules of Court.

During the hearing, testimonies were presented, including that of the natural mother of the child and a social worker from the Department of Social Welfare and Development, who endorsed the adoption as being in the child's best interest. On May 30, 1989, the RTC granted the adoption and allowed the name correction, stating that the correction was a clerical error and could be addressed within the same proceeding to avoid multiple actions.

The Solicitor General appealed the RTC's decision, reiterating the argument against the name correction and claiming that the RTC lacked jurisdiction due to a discrepancy in the name published in the notice.

Legal Issues:

1. Did the RTC acquire jurisdiction over the petition for adoption despite the discrepancy in the name published in the notice?
2. Was the RTC correct in allowing the correction of the minor's name in the civil registry within the same adoption proceeding?

Arguments:

• Petitioner (Solicitor General):

  • The RTC did not acquire jurisdiction because the notice published did not state the true name of the minor, which constituted a substantial defect.
  • The correction of the name should not be allowed in the same proceeding as the adoption, as it pertains to a separate matter under Rule 108.

• Respondents (Private Spouses):

  • The name discrepancy was merely a clerical error and did not affect the identity of the minor.
  • Allowing the correction within the adoption proceeding was practical and served the best interest of the child, preventing unnecessary delays and additional costs.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the RTC's decision regarding the adoption but modified the part concerning the correction of the minor's name. The Court held that the RTC did acquire jurisdiction over the adoption petition despite the name discrepancy, as the error was clerical and did not create confusion regarding the identity of the child. The purpose of the publication requirement was satisfied, as it allowed for any objections to be raised.

However, the Court found that the RTC erred in granting the name correction. It ruled that Rule 108 of the Rules of Court applies to the correction of entries in the civil registry, including changes of name. The Court emphasized that the local civil registrar must be made a party to the proceedings, and proper notice must be given, which was not done in this case. The absence of the civil registrar as an indispensable party rendered the RTC's decision regarding the name correction void.

Significant Legal Principles Established:

1. The distinction between clerical errors and substantial defects in the context of jurisdiction over adoption petitions.
2. The necessity of compliance with Rule 108 of the Rules of Court for any corrections to entries in the civil registry, including the requirement to include the local civil registrar as a party to the proceedings.
3. The importance of proper notice and publication in legal proceedings concerning changes to civil registry entries.