ROICE ANNE F. FOX v. PHILIPPINE STATISTICS AUTHORITY

FACTS:

Roice Anne F. Fox, the petitioner, married Thomas Kenneth K. Fox in Davao City in October 2012. They eventually moved to Canada and their daughter, Zion Pearl Fox, was born there on June 27, 2015. However, a mistake occurred when the Philippine Consulate Office in Calgary submitted a Report of Birth to the Philippine Statistics Authority (PSA), indicating the child's birthdate as June 27, 2016 instead of 2015. As a result, the petitioner filed a petition before the RTC of Davao City to correct this error. The RTC dismissed the petition for lack of jurisdiction, referring to Rule 108 of the Rules of Civil Procedure. The petitioner then filed a motion for reconsideration, but it was also denied.

ISSUES:

  1. Whether or not the RTC of Davao City has jurisdiction over the petition for correction of entry.

RULING:

  1. The RTC of Davao City does not have jurisdiction over the petition for correction of entry. According to Section 1 of Rule 108 of the Rules of Civil Procedure, any person interested in any act, event, order, or decree concerning the civil status of persons may file a petition for the cancellation or correction of any entry relating thereto with the RTC of the province where the corresponding civil registry is located. In this case, the correction sought by the petitioner involves the report of birth made by the Philippine Consulate Office of Calgary, Alberta, Canada to the PSA office in Manila. Since the correction should be made in Manila and not in Davao City, the RTC of Davao City lacks jurisdiction over the petition.

PRINCIPLES:

  • The venue of a petition for correction of entry in the civil registry is determined by the location of the corresponding civil registry.