REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
CITY OF MANILA
BRANCH 22

IN THE MATTER OF PETITION

FOR CORRECTION OF THE
CERTIFICATE OF LIVE BIRTH OF
AGNES PAYUMO BARTOLO WITH
REGISTRY NO. 4931 (K64)

GRACE PAYUMO BARTOLO-

BAYNA,
Petitioner,
-versus- Special Proc. Case No:
R-MNL-19-08232-SP

CIVIL REGISTRAR OF MANILA

AND ALL PERSONS/ENTITIES
WHICH MAY BE AFFECTED
THEREBY,
Respondents.

x-------------------------------------------x

AMENDED PETITION

Petitioners, thru counsel, unto this Honorable Court, respectfully

state that:

1. Petitioner, GRACE PAYUMO BARTOLO-BAYNA, is of legal age,

Filipino, married to Gerardo P. Bayna, and with postal address at
21 E Reyes Compound 1 Road 3, San Miguel Heights Subd.,
Marulas, Valenzuela City;

2. Respondent Local Civil Registrar of the City of Manila, is a public

officer mandated to perform the civil registration including the
cancellation/correction of entries in the civil registry of the City of
Manila where the fact of birth of Petitioner was registered, whose
office is located at Room 117 to 119, 1st Floor, Manila City Hall,
Mayor Antonio J. Villegas Road, Manila, 1000 Metro Manila where
they may be served with summons and other court processes;

3. Petitioner’s parents namely, CIPRIANO SUNGA BARTOLO and

FRANCISCA BARTOLO, were married on August 6, 1952;
4. The union of Petitioner’s parents were blessed with four (4)
children namely:
a. Merlina P. Bartolo – born on April 27, 1953
b. Crisanta P. Bartolo-Ferrer – born on Nov 1, 1954
c. Madonna P. Bartolo-Castañeda – born on May 22, 1957
d. Grace P. Bartolo-Bayna - born on Nov. 9, 1964

5. Since Petitioner’s birth, she was raised and called by both her
friends and family by the name of GRACE PAYUMO BARTOLO;

6. Petitioner was baptized with the Roman Catholic Church under

the name of GRACE PAYUMO BARTOLO;

7. Petitioner started her education and entered Primary School and

eventually finished her College Degree using the name of GRACE
PAYUMO BARTOLO;

8. On July 7, 1987, Petitioner married Gerardo P. Bayna under the

name of GRACE PAYUMO BARTOLO;

9. Petitioner’s union with her husband was soon blessed with two
(2) children namely, Gerard John Bartolo Bayna, who was born on
April 26, 1989, and Gio Matthew Bartolo Bayna, who was born on
April 29, 1995;

10. Both of Petitioner’s children were registered with GRACE

PAYUMO BARTOLO as their mother;

11. Petitioner was able to secure various government issued

Identification cards under the name of GRACE PAYUMO
BARTOLO;

12. Previously, when Petitioner was requesting the then

National Statistics Office for a copy of her birth certificate, she was
issued a copy of her birth certificate with the name of GRACE
PAYUMO BARTOLO;

13. On or about March of 2019, when Petitioner had requested

the Philippine Statistics Authority for a copy of her Birth
Certificate, it was discovered that her mother had made two (2)
registrations of Petitioner’s birth and that another copy of her
birth certificate was existing with the name of “AGNES PAYUMO
BARTOLO”;

14. It was discovered that on November 16, 1964, Petitioner’s

mother, Francisca Bartolo, had registered Petitioner’s birth and
 had registered the same with the name of “AGNES PAYUMO
BARTOLO” ;

15. Petitioner’s mother then made a subsequent registration of

Petitioner’s birth on March 7, 1977 and had registered the same
with the name of GRACE PAYUMO BARTOLO;

16. Petitioner had lived all her life unaware of the earlier
registration made by her mother of her birth with the name of
“AGNES PAYUMO BARTOLO”;

17. Petitioner was never once called nor had represented

herself as “AGNES PAYUMO BARTOLO”;

18. All throughout Petitioner’s life, she was raised and had
conducted herself under the name of GRACE PAYUMO BARTOLO
with all her dealing, both public and private;

19. Both of Petitioner’s parents are already deceased and it is

now impossible to determine and to discover the circumstances
why Petitioner’s mother made two (2) registrations of Petitioner’s
birth and the reason why Petitioner was raised using the name
GRACE PAYUMO BARTOLO all the while there was a prior
registration of her birth under the name of “AGNES PAYUMO
BARTOLO”;

20. From the foregoing circumstances, Petitioner currently has

TWO (2) Certificate of Live Births;

21. All of Petitioner’s dealings were conducted under the name

of GRACE PAYUMO BARTOLO and all existing records were
recorded under the said name;

22. There were no instances wherein Petitioner had used the

name of “AGNES PAYUMO BARTOLO” or that she was even aware
of the existence of the said name prior to the request from the
Philippine Statistics Authority of her Birth Certificate in March
2019;

23. Petitioner now comes seeking this Honorable Court to grant

her prayer for the correction of the Certificate of Live Birth of
“AGNES PAYUMO BARTOLO” with Registry No. 4931 (K64);

24. Attached to the petition are the following documents, to wit:

Annex “A” Certificate of Live Birth of Agnes Payumo Bartolo with

Registry No. 4931 (K64);
 Annex “B” Certificate of Live Birth of Grace Payumo Bartolo with
Registry No. 212 (0-77)
Annex “C” Baptismal Certificate Grace Payumo Bartolo
Annex “D” Elementary Report Card from Constantino Elementary
School of Grace Payumo Bartolo
Annex “E” High School Report Card from Manila Central University
of Grace Payumo Bartolo
Annex “F” Transcript of Record from Centro Escolar University of
Grace Payumo Bartolo
Annex “G” College Diploma of Grace Payumo Bartolo
Annex “H” Marriage Contract of Gerardo P. Bayna and Grace P.
Bartolo
Annex “I” Certificate of Live Birth of Gerard John Bartolo Bayna
Annex “J” Certificate of Live Birth of Gio Matthew Bartolo Bayna
Annex “K” Philippine Passport of Grace Payumo Bartolo-Bayna
Annex “L” Driver’s License of Grace Payumo Bartolo-Bayna
Annex “M” Affidavit of Merlina P. Bartolo
Annex “N” Affidavit of Madonna P. Bartolo-Castañeda
Annex “O” Authenticated Death Certificate of Cipriano Sungra
Bartolo
Annex “P” Authenticated Death Certificate of Francisca Bartolo

WHEREFORE, premises considered, it is most respectfully prayed

of this Honorable Court that the instant petition be GRANTED, ordering
the Local Civil Registrar of Manila to make the necessary correction in
the Certificate of Live Birth of AGNES PAYUMO BARTOLO with Registry
No. 4931 (K64), to wit:.

Erroneous Entries Correct Information

Entry 5 – Name
Agnes Payumo Bartolo Grace Payumo Bartolo

Other reliefs and remedies available under the premises are

likewise prayed for.

Valenzuela City, October 18, 2019

ATTY. CRISTOPHER JON DR. REYES

Counsel for the Petitioner
27 Little Baguio Street, Marulas,
Valenzuela City
Roll No. 71475
PTR No. 5872711
Issued on Jan. 3, 2019 at Valenzuela City
MCLE Compliance No. VI – 0024228
Valid until April 14, 2022
 VERIFICATION AND CERTIFICATION
OF NON-FORUM SHOPPING

Republic of the Philippines }

Valenzuela City, Philippines } S.S.
X-------------------------------------------------X

I, GRACE PAYUMO BARTOLO-BAYNA, of legal age, Filipino,

married to Gerardo P. Bayna, and with postal address at 21 E Reyes
Compound 1 Road 3, San Miguel Heights Subd., Marulas, Valenzuela
City, do hereby depose and state under oath that:

1. I am the petitioner in the above entitled case;

2. I have caused the preparation and filing of this petition;
3. I have read and understood the contents of said petition and that
all the allegations contained therein are true and correct of my
personal belief and knowledge;
4. I have not heretofore commenced any other action involving the
same issue in the Supreme Court, the Court of Appeals or any
other tribunals or agency involving the same cause of action;
5. To the best of my knowledge no such action or proceedings are
pending in the Supreme Court, the Court of Appeals or different
divisions thereof, or any other tribunals or agency involving the
same cause of action;
6. If I should then learn the same, I undertake to promptly inform
the aforesaid and/or other Court of Tribunal or agency of the fact
within five (5) days therefrom.

IN WITNESS WHEREOF, I hereunto voluntarily affix my signature

this _______________________at Valenzuela City.

GRACE PAYUMO BARTOLO-BAYNA

Affiant

SUBSCRIBED AND SWORN to before me this ______________ at

Valenzuela City. Affiant exhibited to me her Driver’s License with No.
N25-04-1070039 an identification card issued by a public office with
the picture and signature of the affiant.

Doc. No. ______;

Page No. _____;
Book No. _____;
Series of 2019.