RP vs.

Unabia
GR No. 213436

Facts
A petition for correction of Entries for the birth Certificate was filed by one Miller Omandam
Unabia concerning the erroneous entry of the gender as “female” instead of “male”, spelling
mistake in the first name and the middle name. The petition was supported by various
documents with the medical certificate supporting the change regarding the erroneous gender
entry. The RTC ordered the correction of the entries and upon appeal the CA reaffirmed the
lower court’s decision. The state challenged the decision elevating the matter to the Supreme
Court.

Issue
Whether or not the failure of the Medical Certificate to indicate that the petitioner “has not
undergone sex change or transplant” affects the authenticity of the evidence as required by RA
9048

Held
No, the medical certificate is a public document issued by a public officer in their official capacity
thus does not need to be authenticated.
Citing Patula vs People* the SC stated that "A public document, by virtue of its official or
sovereign character, or because it has been acknowledged before a notary public (except a
notarial will) or a competent public official with the formalities required by law, or because it
is a public record of a private writing authorized by law, is self-authenticating and requires
no further authentication in order to be presented as evidence in court." There is no need to
follow the formal requirement under RA 9048 as the medical certificate is a public document
stating that Miller is “phenotypically male”.
The SC also stated that under Section 23, Rule 132 of the Rules of Court that public documents
are considered to be prima facie evidence of everything that is contained within the documents
thus the findings under the medical certificate concerning Miller’s physical, physiological and
biochemical makeup is sufficient evidence enough to support that he was a male his whole life
and has not undergone sex change. Thus the medical certificate alone can wholly support the
correction for the error in the entry of gender and can do away with the requirement of “has not
undergone sex change or transplant” certification.

*Patula vs. People, 685 Phil. 376, 397 (2012)