Branch Clerk of Court (BCC): IN THE MATTER OF CANCELLATION/

CORRECTION OF ENTRIES IN THE CERTIFICATE OF LIVE BIRTH OF RAMON

CORPUS TAN KO, Petitioner vs. CIVIL REGISTRAR OF MANILA,
AND ALL PERSONS/ENTITIES WHO/WHICH MAY BE AFFECTED THEREBY,
Respondents., Spec. Proc. No. 12-34567

Appearances

Counsel for the Petitioner (CTP): Good afternoon, your honor. I am Atty.
_________respectfully appearing for the Petitioner.

Counsel for the Respondent (CTR): Good afternoon, your honor. I am Atty. _______
of the Office of the Solicitor General respectfully appearing for the respondent.

BCC: Are you ready for preliminary conference?

CTP: Yes, your honor.

CTR: Yes, your honor.

CTP: Your honor, for the petitioner, we respectfully submit the following admitted facts
and proposed stipulation of facts:

1. The Honorable Court has jurisdiction over the case;

2. That the petitioner has satisfied the requirements of an adversarial proceeding
based on Rule 108 of the Rules of Court;
3. That the petitioner was born on November 13, 1965 at St. Paul Hospital in the
City of Manila;
4. That the petitioner’s birth was duly registered in the civil registry of Manila;
5. That the petitioner had been using his real name "Ramon Corpuz Tan" during his
lifetime;
6. That the petitioner after he secured a copy of his Certificate of Live Birth, he
discovered that his name was entered as "Ramon Corpus Tan Ko" instead of his
true and correct name which is "Ramon Corpuz Tan";
7. That the said aforesaid material errors and mistakes in the entries of his
Certificate of Live Birth were due to inadvertence and error of the hospital
personnel who prepared the subject certificate; that "Ko," which was the first
name of his father, was inadvertently included in his last name;
8. that the mistake was not immediately rectified because the petitioner only
discovered the same, after having his own children.

CTR: Your honor, for the respondent, we respectfully submit the following:

1. We admit petitioner’s first proposed stipulation;

2. We deny petitioner’s second proposed stipulation;
3. We admit petitioner’s third proposed stipulation;
 4. We admit petitioner’s fourth proposed stipulation;
5. We admit petitioner’s fifth proposed stipulation;
6. We admit petitioner’s sixth proposed stipulation;
7. We deny petitioner’s seventh proposed stipulation;
8. We admit petitioner’s eight proposed stipulation.

CTP: Your honor, as for the statement of the issue for the petitioner, we respectfully
submit the following:

1. Whether or not the petition for correction of entry is valid and meritorious based
on prevailing laws and jurisprudence;
2. Whether or not the respondent the Civil Registrar of Manila committed an error to
grant the petition for correction of entry filed by the petitioner.

CTR: Your honor as for the statement of the issue for the respondents, we respectfully
submit the following: –
1. Whether or not the petition for correction of entry is valid and meritorious
based on prevailing laws and jurisprudence;
2. Whether or not the respondent the Civil Registrar of Manila committed an
error to justify the petition for correction of entry filed by the petitioner.

CTP: Your honor as for the petitioner, the following are the documentary evidence to be
pre-marked as exhibits:

1. Exhibit A – Petitioner’s Judicial Affidavit

Purpose: To serve as a direct testimony of the petitioner in relation to the petition
for the correction of entries in the certificate of live birth.

2. Exhibit B – Certificate of Live Birth indicating petitioner's name as "Ramon

Corpus Tan Ko
Purpose: To prove that there is a material error in the entry of name of the
petitioner.

3. Exhibit C - BIR Identification Card indicating petitioner's name as "Tan Ramon

Corpuz
Purpose: To prove that petitioner uses the said complete name in all public
documents and identification cards.

4. Exhibit D - Firearm License Card indicating petitioner's name as "Tan, Ramon

Corpuz"
Purpose: To prove that petitioner uses the said complete name in all public
documents and identification cards.

5. Exhibit E - PhilHealth Identification Card indicating petitioner's name as "Tan,

Ramon Corpuz"
 Purpose: To prove that petitioner uses the said complete name in all public
documents and identification cards.
6. Exhibit F – Petitioner’s Certificate of Marriage
Purpose: To prove that petitioner uses the said complete name in all public
documents and identification cards.
7. Exhibit G – Certificates of Live Birth of petitioner's children
Purpose: To prove that petitioner uses the said complete name in all public
documents and identification cards.

CTR: Your honor as for the respondents, the following are the documentary evidence to
be pre-marked as exhibits:
1. Exhibit 1 – Judicial Affidavit of Jose Dela Cruz, the Civil Registrar of Manila
Purpose: To serve as a direct testimony of the petitioner in relation to the petition
for the correction of entries in the certificate of live birth.

2. Exhibit 2 - Petition for Correction of Entry filed by the Petitioner

Purpose: To prove that the petitioner’s petition failed to implead and notify the
affected or interested parties as mandated under Rule 108 of the Rules of Court;

CTP: Your honor, for the petitioner, we have one witness:

1. Ramon Corpuz Tan to testify on the contents of his judicial affidavit and matters
pertinent to the proceeding.

CTR: Your honor, for respondent, we have one witness:

1. Jose Dela Cruz, the Civil Registrar of Manila to testify in relation the contents of
his judicial affidavit and matters pertinent to the proceeding.

BCC: After finding the petition sufficient in form, the case is set the for hearing on April
25, 2021.