G.R. No.

170645

Baldos v. Court of Appeals

9 July 2010

Facts:

Although born in 1948, Reynaldo Pillazar, better known as Reynaldo Baldos, was not
officially registered until 1985. His father, Bartolome Baldos, and mother, Nieves Baldos, were
named on his certificate of live birth. Nieves Baldos contested the late registration in a 1995 case
she filed in the Olongapo City Regional Trial Court, stating that Reynaldo was not her son.

The trial court rejected a complaint over the plaintiff's relationship with the father, noting
that the plaintiff's assertion that the defendant was her son was refuted by the facts. The court
determined that the best proof of the parties' connection was found in the documents on file, and
the plaintiff's conduct did not justify disowning the oppositor. The court further stated that
although an act of ungraciousness may give rise to disinheritance, it is not grounds for nullifying a
duly executed instrument or depriving someone of filiation. Nieves filed an appeal with the Court of
Appeals in spite of this, claiming that Reynaldo's birth certificate was not registered promptly
enough in accordance with Presidential Decree No. 651.

In 2005, the Court of Appeals upheld an order from the trial court declaring that P.D. No.
651 did not forbid those born before January 1, 1974, from registering their births later. The ruling,
the court noted, was intended to promote the recording of births and deaths. Nieves Baldos's
attorney submitted a move for substitution in 2005 following her death in 1999, and the court
allowed it. Nieves Baldos was then succeeded by Bartolome's brothers, Francisco and Martin
Baldos.

Issue:

Whether it is legitimate for Reynaldo's birth to have been registered late.

Ruling:

The petition was DENIED due to the lack of MERIT. The petitioners contend that P.D. does
not permit Reynaldo's birth to be registered after the fact. No. 651, asserting that it is only
applicable to births that occur between January 1, 1974, and the day the decree went into force.
They contend that Reynaldo was born on October 30, 1948, which is not within the decree's
coverage period. The petitioners claim that in interpreting P.D., the Court of Appeals disregarded
fundamental principles of statutory interpretation. Number 651 to encompass births prior to
January 1, 1974.

Reynaldo argues against P.D. The late registration of anyone born before January 1, 1974, is
not prohibited by No. 651. In addition, he argues that a certificate of live birth is a public record
protected by the presumption of regularity in the exercise of official tasks and that he has amply
demonstrated that he is the son of Nieves and Bartolome Baldos.

In order to address the issue of under-registration of births and deaths, Presidential Decree
No. 651, also known as An Act Requiring the Registration of Births and Deaths in the Philippines,
which Occurred from January 1, 1974 and Thereafter, allows for special registration within a set
amount of time. Act No. 3753, often known as the Civil Registry Law, came into force on February
27, 1931, and applies to Reynaldo's late registration of birth because he was born on October 30,
1948.

The court contends that Reynaldo's live birth certificate is deemed to have completed the
legal procedure for late birth registration because it is a properly registered public record. The
petition to annul Reynaldo's birth was properly rejected for lack of merit both the trial court and
the Court of Appeals.