FACTS:
Francler Onde filed a petition to correct entries in his birth certificate: (1) parents' marital status from "married" to "not married"; (2) mother's first name from "Tely" to "Matilde"; and (3) his first name from "Franc Ler" to "Francler." The RTC dismissed the petition.
ISSUE:
Whether the corrections sought can be granted and through what proceedings?
RULING:
The Supreme Court affirmed the dismissal but declared it without prejudice:
First name corrections (his and his mother's) can be done administratively under R.A. 9048 by the city civil registrar—no judicial order needed.
Legitimacy correction (changing parents' status from married to not married) is substantial and requires adversarial proceedings under Rule 108, with all interested parties (parents) impleaded.
Petitioner failed to implead necessary parties (his parents) as required by Rule 108, Section 3.
DOCTRINE:
R.A. 9048 allows administrative correction of clerical/typographical errors and first name changes without judicial order
Substantial corrections (affecting legitimacy, citizenship, filiation) require adversarial proceedings under Rule 108 with all interested parties impleaded
Civil registrar alone is insufficient as respondent for substantial corrections