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REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

FIFTH JUDICIAL REGION

Branch 4

Legazpi City

IN THE MATTER OF CANCELLATION/

CORRECTION OF ENTRIES IN THE

CERTIFICATE OF LIVE BIRTH OF

ALANIS S. MOROSOT

Petitioner,

---versus--- Special Proc. No. _________

CIVIL REGISTRAR OF LEGAZPI CITY

AND

CIVIL REGISTRAR GENERAL

Respondents.

x--------------------------------------x

PETITION

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


_____________________________.

NOTARY PUBLIC

Doc. No. _____;


Page No. _____;
Book No. _____;
Series of _____;

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