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MA. CRISTINA TORRES BRAZA v. CITY CIVIL REGISTRAR OF HIMAMAYLAN CITY

FACTS:

Ma. Cristina Torres and Pablo Sicad Braza, Jr. were married and had three children together. However, Pablo died in a vehicular accident. During Pablo's wake, Lucille Titular introduced a minor named Patrick Alvin Titular Braza as her and Pablo's son. Ma. Cristina obtained Patrick's birth certificate, which indicated that he was legitimated by the marriage of Lucille and Pablo. Ma. Cristina then filed a petition to correct the entries in Patrick's birth record, arguing that the marriage of Lucille and Pablo was bigamous and that Patrick's paternity and filiation needed to be established through DNA testing. The trial court dismissed the petition, stating that it did not have jurisdiction to nullify marriages and rule on legitimacy and filiation in a special proceeding for correction of entry.

ISSUES:

  1. Whether the trial court has jurisdiction to nullify marriages, rule on legitimacy and filiation, and order DNA testing in a special proceeding for correction of entry.

  2. Whether the petition for correction of entries in Patrick's birth record is the proper remedy for questioning the validity of the marriage and Patrick's legitimacy.

RULING:

  1. The Supreme Court held that the trial court does not have jurisdiction to nullify marriages, rule on legitimacy and filiation, and order DNA testing in a special proceeding for correction of entry. Rule 108 of the Rules of Court only allows the correction of clerical errors in civil registry entries, while substantial or contentious alterations require adversarial proceedings. The petition filed by Ma. Cristina sought to nullify the marriage between Pablo and Lucille and impugn Patrick's legitimacy, which are governed by different laws and should be filed in a Family Court. The Court emphasized that the validity of marriages, legitimacy, and filiation can only be questioned through a direct action, not through collateral attack. The cases cited by the petitioners, Cariño v. Cariño, Lee v. Court of Appeals, and Republic v. Kho, were distinguished from the present case because they involved different factual circumstances.

PRINCIPLES:

  • A special proceeding for correction of entry under Rule 108 of the Rules of Court is limited to correcting clerical errors in civil registry entries.

  • Substantial or contentious alterations to civil registry entries require adversarial proceedings.

  • The validity of marriages and questions on legitimacy and filiation can only be properly addressed in a direct action filed in a Family Court.

  • Collateral attacks on the validity of marriages, legitimacy, and filiation are not allowed.