You are on page 1of 5

Clerk of Court: All rise. The court is now in session, silence is hereby enjoined Hon.

_________, ( Judge) Presiding.

( Prayer)
Judge:( Stamp gavel thrice) Sit.

CALL THE CASE

Clerk of Court: SPECIAL PROCEEDING CASE NO.__21______


RANDY CHUA vs. THE LOCAL CIVIL REGISTRAROF IRIGA CITY and LEANDRO CHUA KING for the

CORRECTION OF ENTRY IN THE CERTIFICATE OF LIVE BIRTH OF RANDY CHUA TO RANDY MARQUEZ.

Judge: Appearances for Petitioner and Respondent

Petitioner’s Counsel: Your Honor, I am Atty . Porenz Vargas appearing for the
petitioner in this case .Ready to prove the jurisdictional facts your Honor.

Respondent’s Counsel : Your honor, I am Atty. Joya Resoco appearing as Respondent’s


counsel .Ready your honor.

Judge: Now, will the distinguished counsel of the petitioner prove the jurisdictional facts of
the petition:

( PROVING OF JURISDICTIONAL FACTS):

Petitioner’s Counsel: May it please the court.

I'd like to ask the court to mark the following exhibits proving
compliance with the Jurisdictional requirements.
Judge: Now, we proceed to the facts , and pieces of evidence to be presented by
both parties. Petitioner’s counsel may start.

Petitioner’s Counsel: Thank you, your Honor. I have here with me your Honor ,documentary and
some object evidence which I move to be marked as Exhibit 1 to Exhibit C. Your honor, Exhibit
1 is Petition for Change of Name of RANDY CHUA to RANDY MARQUEZ and
Correction of Entry in Certificate of Birth consisting of six (2) pages:
JUDGE: Mark it.

Petitioner’s Counsel: Your Honor, Exhibit "A-1"-Petitioner's signature in the Verification


and Certification of Non-Forum Shopping :
JUDGE: Mark it.

Petitioner’s Counsel: Your Honor, Exhibit "B"-Amended Order of the Court dated
November 14, 2021 giving due course and setting the petition for hearing
JUDGE: Have it marked .

Petitioner’s Counsel : Your Honor, Exhibit "B-1" Notice sent to Office of the Solicitor
General
JUDGE: Have it marked .

Petitioner’s Counsel: Your Honor, Exhibit "B-2"-Notice of Appearance of the Solicitor


General with Authority to the Office of the City Prosecutor of Iriga City to appear in
this case
JUDGE: Have it marked .

Petitioner’s Counsel: Your Honor, Exhibit B.3"-Notice sent to Civil Registar of Iriga City:
JUDGE: Have it marked .
Petitioner’s Counsel: Your Honor, Exhibit "C"-Affidavit of publication of the Notice of
Hearing , that it was published in three (3) consecutive weeks specifically
on____________________,which is not within 30 days prior to any election nor within
four (4) months before the hearing of this case :

JUDGE: Have it marked .

Any further comments counsel? Ms. Clerk of Court , please take note . Are there any
exhibits and documents to be presented petitioner’s counsel?

Petitioner’s Counsel: None your Honor.

We pray that said exhibits be admitted in evidence Likewise we pray that we be


allowed to present additional evidence and this further reception of pieces of evidence
be made before a court-appointed commissioner, Your Honor.
Exhibit "A-1"-

REPUBLIC OF THE PHILIPPINES!


CITY OF IRIGA )S.S.

X-----------------------------------------------------------------X

VERIFICATION AND CERTIFICATION AGAINST FORUM SHOPPING

I , RANDY CHUA, of legal age, Filipino citizen, and hereby declare under oath
that.:
1. I have caused the preparation of the foregoing petition; I have read and
understood the contents of the same; and that all the allegations therein are
true and correct of our own knowledge and based on authentic documents
2. I FURTHER CERTIFY THAT:

a. I have not commenced any proceeding involving the same issues before
the Supreme Court, Court of Appeals, or any other Government Agency
or Tribunal
b. To the best of our knowledge, no such action is pending before the
Supreme Court. Court of Appeals, or any other Government Agency or
Tribunal.
c. If there be any similar action before the Supreme Court. Court of
Appeals. or any other Government Agency or Tribunal, We undertake to
report the same within five (5) days to the court where the original action
and certification referred to herein has been filed.

IN WITNESS WHEREOF, I have hereunto set my hand the 14th day of


November 2021 in the City of Iriga Philippines.

RANDY CHUA

SUBSCRIBED AND SWORN to bere me in the City of Iriga this 14 th day of


November 2021 , by affiant personally known to me, who are the same person who
personally signed before me the foregoing affidavit and acknowledged that he executed
the same

Doc. No. 2
Page No. 4
Book No.2
Series of 2021

ATTY. PORENZ VARGAS


Counsel for the Petitioner
Exhibit 1

Republic of the Philippines


REGIONAL TRIAL COURT
Branch 2
Iriga City

In the Matter of :

CORRECTION OF ENTRY
IN THE CERTIFICATE OF LIVE BIRTH OF
RANDY CHUA TO RANDY MARQUEZ

Petitioner, SPECIAL PROCEEDING


CASE NO.__21______

-versus-

THE LOCAL CIVIL REGISTRAR


OF IRIGA CITY and LEANDRO CHUA KING

Respondent.

X--------------------------------------------------------------------------------------------------------------------------------------X

PETITION

WITH ALL DUE RESPECT TO THE HONORABLE COURT, the Petitioner,


through counsel, and unto the Honorable Court, states that:

1. The petitioner is of legal age with postal address at Iriga City


2. The Local Civil Registrar is a government entity charged with the recording,
registration, and custody of public records and other matters with postal address at
the Iriga City.
3. Petitioner was born on MARCH 1, 1996, and is the natural child of MARIA
MARQUEZ and LEANDRO CHUA KING. Said birth was duly registered with the Local
Civil Registry under Local Civil Registry No. 26-13000. A machine copy of the
Certificate of Live Birth is hereto attached as Annex "A", to form part hereof;
4. In the said Certificate of Live Birth. Petitioner's Last name CHUA, the surname of
his father;
5. The same Certificate of Live birth, also indicates that his birth parents are
MARRIED, instead of not MARRIED during the time of his birth.
Thus, will make him an ILLEGITIMATE CHILD .
6. Moreover, several entry is incorrect, and said information was erroneously entered
by Local Civil Registrar. The clerical error(s) to be corrected is (are)

ITEM NO DESCRIPTION FROM TO


1 PETITIONER’S RANDY CHUA RANDY MARQUEZ
NAME
2 MARRIAGE OF MARRIED NOT MARRIED
PARENTS
7. The errors was made due to mistake of fact, supplied in good faith and without any
unlawful or illegal intention:

8. The Correction being sought is meant to state the truth of (1) his Surname, and (2)
his parent's marriage.

PRAYER

WHEREFORE, premises considered, it is most respectfully prayed of the


Honorable Court that, after due notice and hearing a decision be rendered in favor of
herein Petitioner, ordering the Local Civil Registrar of the City of Iriga to change the
entry in Petitioner's Certificate of Live Birth under the –

(1) FULLNAME OF PETITIONER from " RANDY CHUA “ TO RANDY MARQUEZ”

(2) MARRIAGE OF PARENTS from " MARRIED “ TO " NOT MARRIED".

Such other reliefs as may be just and equitable under the circumstances are
likewise prayed for.

IN WITNESS WHEREOF, I have hereunto set my hand this 14 th day of


November 2021 in the City of Iriga, Philippines.

ATTY. PORENZ VARGAS


Counsel for the Petitioner

You might also like