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Republic of the Philippines

REGIONAL TRIAL COURT


2ND Judicial Region
Branch __
Tuguegarao City, Cagayan

IN RE: PETITION FOR CORRECTION


OF ENTRY IN THE CERTIFICATE OF
LIVE BIRTH OF JACKIELOU T. QUILANG,
PARTICULARY THE YEAR OF HER BIRTH
OMMITED WHICH IS 1987,

SP PRO. CASE NO.

JACKIELOU TAMAYO QUILANG


Petitioner.

-vs-

CIVIL REGISTRAR OF TUGUEGARAO CITY,


AND THE NATIONAL STATISTIC OFFICE
Respondents.
X - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - x

PETITION

COMES NOW, the Petitioner, thru the PUBLIC ATTORNEYS

OFFICE, by the undersigned counsel, respectfully avers to this

Honorable Court the following, to wit:

1. That Petitioner is a Filipino, of legal age, single, and a resident

of Centro 12, Balzain, Tuguegarao City, Cagayan, where she

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may be served with summons and other processes of the

Honorable Court;

2. That the respondents are the public official-in-charge of the

custody, issuances and release of birth certificates in the City

of Tuguegarao, Cagayan whose official address is at THE

OFFICE OF THE CITY CIVIL REGISTRAR, Tuguegarao City,

Cagayan and the other respondent is the National Statistics

Office located in Tuguegarao City, Cagayan where they may be

served with notices and other court processes of this Court;

3. That the petitioner intends to apply for Passport in order to

work abroad and to take midwifery board examination;

4. That, as she was preparing her required papers, she found out

that there is an entry omitted in her birth certificate;

5. Instead of the entry supposed to be appearing therein as her

birth year is 1987, there was no entry appearing therein re

birth year. Upon perusal of her certificate of live birth issued

by the local civil registrar, it appears therein that her birth

year is 1987 but on her birth certificate issued by the National

Statistics Office, there was no birth year indicated therein. A

copy of her original birth certificate issued by the Local Civil

Registrar as well as a copy in Certificate of Live Birth from the

National Statistics Office are hereto attached and marked as

Annexes A and B;

6. The petitioner knows herself and is widely known in her

community that she was born in the year 1987. Attached

hereto is a copy of her Transcript of Records from Cagayan

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National Highschool and her Baptismal Certificate from

Christ-Centered Life Church Mission International Inc.

showing that the Petitioner was born in the year 1987, marked

as Annex C and D .

7. The other residents of their community can attest thereto that

she was indeed was born in the year 1987 of her parents.

Attached hereto is a Joint Affidavit of two disinterested

persons to prove that it is a well known knowledge in their

community that the petitioner was born in the year 1987,

marked as Annex E.

8. This petition was filed not for the purpose of evading any

obligation, be it civil, criminal or administrative;

9. The petitioner prays for the correction and addition of the

omitted entry in her birth certificate as a corrected birth

certificate is a requirement for the application of the passport

in order to acquire working visa abroad.

PRAYER

WHEREFORE, it is respectfully prayed to the Honorable Court

to ORDER the Civil Registrar of Tuguegarao City, Cagayan, and

subsequently the record of the National Statistic Office, to rectify

the erroneous and omitted entry of the birth certificate of

JACKIELOU TAMAYO QUILANG so that the said certificate should

indicate the true birthdate specially the year of birth of the

petitioner, which is 1987.

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For such other and further relief as this HONORABLE COURT

may deem just and equitable under the premises.

Tuguegarao City, Cagayan, Philippines. March 7, 2017

PUBLIC ATTORNEYS OFFICE


Department of Justice
Tuguegarao City, Cagayan

By:

ATTY. JOEL C. AGRA


Public Attorney I
IBP Lifetime Member No. 012928
Roll No. 63632

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REPUBLIC OF THE PHILIPPINES }
Municipality of Aurora }
Province of Zamboanga del Sur

VERIFICATION and CERTIFICATION AGAINST FORUM


SHOPPING

I, LEGIN TAMPARONG-OY, Filipino, of legal age, single, and a


resident of Poblacion, Lapuyan, Zamboanga del Sur, after having
been sworn to in accordance with law, hereby depose and states
that:

1. I am the Petitioner in the foregoing Special Proceeding


Petition for Correction of Entry In the Certificate of Live Birth before
the Regional Trial Court of Pagadian City, Zamboanga del Sur; That
I have read and understood the allegations therein and that the
same is true and correct to the best of my knowledge and belief;

2. That to the best of my knowledge there is no such action or


proceeding that has been pending involving the same parties and
issues in the Supreme Court, the Court of Appeals or different
divisions thereof, or in any tribunal or agency; That thereafter,
should I learn that a similar action or proceeding has been filed or
is pending in the Supreme Court, the Court of Appeals or different
divisions thereof, or in any tribunal or agency, I will undertake to
report such fact within five (5) days from such notice to such
courts, tribunal or agency for its proper disposition.

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IN WITNESS WHEREOF, I have hereunto affixed my signature
this ___ day of ___________ 2010, in the Municipality of Lapuyan,
Zamboanga del Sur, Philippines.

LEGIN
TAMPARONG OY
Petitioner

SUBSCRIBED AND SWORN to before me this _____ day of


_____________________ 2011 at Aurora, Zamboanga del Sur,
Philippines. Affiant exhibited her Community Tax Certificate No.
23938599 issued at Aurora, Zamboanga del Sur, on _________, ___,
2011.

ATTY. DEONHAR M. CENIZA


IBP No. 736560; 4/26/11;
Pagadian City;
PTR No. 5349742; 1/4/11;
Pagadian City;
Doc. No. 80 Roll of Attorneys No. 57505
Page No. 16 Exempted from MCLE
Compliance
Book No. I Admitted to the BAR on April 2010
Series of 2011.
Copy furnished:

Office of the Municipal Registrar Received by:


____________________;
Aurora, Zamboanga del Sur Signature over

printed name

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Date:

___________________________;

National Statistics Office Received by: CP 002 186 603


PH;
Santa Mesa, Manila City Date: March 21, 2011;

Provincial Prosecutors Office Received by:


____________________;
Justice Hall, Pagadian City Signature over

printed name

Date:

___________________________;

Solicitor General Reg. Receipt No. CP 002


186 617 PH;
Makati City, Philippines Date: March 21, 2011;

EXPLANATION

In compliance with the Rules on the Service of Pleadings, a


copy of this Petition is furnished to the respondents and the
interested office at the addresses below by personal service to the
office of the Municipal Registrar, , Provincial Prosecutor, and by
registered mail with return card due to the office of the Solicitor
General in Makati City and National Statistics Office in Santa Mesa,
Manila City due to the distance between petitioners counsels
address and the respondents.

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DEONHAR M. CENIZA

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