Petitioner, through the undersigned counsel and to this Honorable Court,
most respectfully states that:
1. Petitioner is of legal age, Filipino, single, a resident of 123 Rosas
Street, Nakanam Subdivision, Legazpi City;
2. Public respondent LOCAL CIVIL REGISTRAR OF LEGAZPI CITY, which
is located at Ground Floor, City Hall, City of Legazpi, is the government agent empowered of the registration and cancellation/correction of entries in the Civil Registrar where the fact of birth of the said minor child was registered; 3. Public respondent CIVIL REGISTRAR GENERAL, which is located at 2nd Floor Solicare Building 1, Magsaysay Blvd. Sta. Mesa, Manila, is the government agent empowered to give orders and instructions to the local Civil Registrars with reference to the performance of their duties as such;
4. Petitioner is the daughter of Spouses Liza M. Segue and Merto G.
Morosot, born on February 14, 1989 in Legazpi City. A copy of the Baptismal Certificate issued by the Parish of St. Raphael, Legazpi City is hereunto attached as Annex “A;”
5. Unfortunately, in recording the facts of her birth, the personnel of the
Local Civil Registrar of Legazpi City, thru inadvertence and mistake, erroneously entered in the records the date of birth of the petitioner as “February 14, 1969” instead of “February 14, 1989.” A copy of the Certificate of Live Birth of Alanis S. Morosot issued by the National Statistics Office (NSO) and Certification from the Local Civil Registrar of Legazpi City are hereunto attached as Annex “B” and Annex “C” respectively;
6. To sustain Petitioner’s claim, attached hereto are: the earliest school
records of Petitioner from PiaShine International School, and a photocopy of her Postal Identity Card, as Annex “D” and Annex “E” respectively; and
7. In order to correct the aforementioned erroneous entry in her
Certificate of Live Birth of, Petitioner hereto files the instant Petition pursuant to Rule 108 of the Revised Rules of Court;
8. This petition is intended neither for the Petitioner to escape criminal
and/or civil liability, nor affect the hereditary succession of any person whomsoever but solely for the purpose of setting the records of herein petitioner straight.
PRAYER
WHEREFORE, premises considered, it is most respectfully prayed to this
Honorable Court that an Order be issued directing the herein Respondent – Civil Registrars to correct the information supplied as the Petitioner’s date of birth in her Certificate of Live Birth. Other reliefs just and equitable are likewise prayed for.
Legazpi City. February 10, 2020.
ATTY. GATULBO RAYCO
Counsel for the Petitioner 216 PVLB 15 Bldg., Legazpi City PTR No. 00696969/Jan. 3, 2020/Legazpi City IBP NO. 906969/Jan. 3, 2020/Legazpi City Chapter Attorney’s Roll No. 69696/MCLE Compliance IV-0010420
REPUBLIC OF THE PHILIPPINES)
CITY OF LEGAZPI )SS
VERIFICATION AND CERTIFICATION
AGAINST FORUM-SHOPPING
I, ALANIS S. MOROSOT, single, of legal age, Filipino and a resident of
123 Rosas Street, Nakanam Subdivision, Legazpi City, after having been duly sworn to in accordance with law, do hereby depose and state that:
1. I am the Petitioner in the foregoing Petition and I have caused
the preparation of the same, the contents of which are all true and correct to the best of my personal knowledge, information and belief;
2. I certify that neither have I commenced nor is there any pending
Petition of similar nature before any court, tribunal or quasi-judicial agency, and if I should hereafter learn that the same or similar Petition has been filed or is pending in any court, tribunal or quasi-judicial agency, I shall report the fact within five (5) days therefrom to this Honorable Court.
IN WITNESS WHEREOF, I have hereunto set my hand this 10th day of
February, 2020 in Legazpi City. ALANIS S. MOROSOT
Affiant
SUBSCRIBED AND SWORN to before this ______ day of ________________, 20___ at