PUBLIC ATTORNEY'S OFFICE

Double K Shell Station,

PAO MAIL – FREE
PRIVATE OR
Masaya, Rosario
UNAUTHORIZED USE TO
4225 Batangas
AVOID PAYMENT OF
POSTAGE IS PENALIZED BY
FINE OR IMPRISONMENT OR
BOTH PURSUANT TO RA 9406
(PAO LAW)

OFFICE OF THE LOCAL CIVIL REGISTRAR

Municipal Hall Building
Rosario,
4224 Batangas
 REPUBLIC OF THE PHILIPPINES
REGIONAL TRIAL COURT
FOURTH JUDICIAL REGION
BRANCH 87
Rosario, Batangas
RE: PETITION FOR
CORRECTION OF THE
DATE OF BIRTH IN THE
CERTIFICATE OF LIVE BIRTH
OF LUCIA DE CASTRO
CARANDANG WITH LOCAL
CIVIL REGISTRAR NO. 11 FROM
DECEMBER 13, 1967 TO
DECEMBER 3, 1968

LUCIA CARANDANG BELGAR, SP. PROC. _______

Petitioner,

-versus-

THE LOCAL CIVIL REGISTRAR

OF PADRE GARCIA, BATANGAS,
NATIONAL STATISTICIAN AND
CIVIL REGISTRAR GENERAL OF
THE PHILIPPINE STATISTICS
AUTHORITY, and ALL PERSONS
WHO MAY HAVE CLAIM,
INTEREST OR WOULD BE
AFFECTED BY THIS PETITION.
Respondents.

X------------------------------------------------------X

PETITION
COMES NOW, the Petitioner, through Public Attorney’s Office,
by the undersigned counsel, and unto this Honorable Court, most
respectfully alleges that:

1. The Petitioner is of legal age, married, Filipino and a

resident of Brgy. Maugay East, Padre Garcia, Batangas
where she may be served with notices, orders and
other court processes;

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2. Respondents Local Civil Registrar (LCR) of Padre
Garcia, Batangas and National Statistician and Civil
Registrar General of Philippine Statistics Authority
are impleaded as party Respondents considering that
they are the keepers of the official records of birth of
LUCIA DE CASTRO CARANDANG. Their offices are
at the Municipal Hall Building, Poblacion, Padre
Garcia, Batangas, and Office of the National
Statistician, 17th Flr. CyberPod Centris, Eton Three,
EDSA, Quezon City, 1101, respectively, where they
may be served with orders, notices, and other court
processes;

3. The Petitioner was born on December 3, 1968 at

Brgy. Maugat, Padre Garcia, Batangas to Spouses
Leopoldo Carandang and Nelia De Castro;

4. When the petitioner secured a copy of her Certificate

of Live Birth, she discovered that her date of birth
therein was erroneously entered as DECEMBER 13,
1967. Attached herewith and made an integral part
hereof as ANNEX “A” is a photocopy of her
Certificate of Live Birth from Philippine Statistics
Authority, with Local Civil Registrar No. 11, and as
ANNEX “B” is a copy of her Certificate of Live Birth
issued by the Office of the Municipal Registrar Padre
Garcia, Batangas, with Local Civil Registrar No. 11;

AS TO HER DATE OF BIRTH

5. The true and correct date of birth of the petitioner is

“December 3, 1968” as indicated in her same
Certificate of Baptism which is attached hereto and
marked as Annex C;

6. Likewise, her true and correct date of birth,

“December 3, 1968”is reflected in Palagiang Talaan
ng Mag-aaral sa Sekundarya issued by Sto. Rosario
High School, Alupay, Rosario, Batangas. A copy of
said document is attached hereto and marked as
Annex D;

7. Petitioner has been using “December 3, 1968” as

her correct date of birth in all her identification card
such as her Voter’s Identification Card and Social
Security System Identification Card. Attached
herewith and made an integral part hereof as ANNEX
“E” is a copy of her Voter’s Identification Card issued

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 by the Commission on Elections, Padre Garcia,
Batangas with VIN 1020-0055B-LO36820000 and as
ANNEX “F” is a copy of her SSS Identification Card
issued by the Social Security System Corporation, with
number 33-3130500-2;

8. Petitioner is now married to Santos B. Belgar and in

her Certificate of Marriage, she used her true and
correct date of birth of December 3, 1968. A copy of
said document is attached hereto and marked as
Annex “G”.

9. Petitioner is the third (3rd) and youngest of the

Carandang siblings. At the time of her birth, her eldest
sibling, Melinda Carandang, was thirteen (13) years
old, as she was born on November 8, 1955 while her
second sibling, Ramon Carandang, was eight (8) years
old as he was born on August 9, 1960. Attached
herewith and made an integral part hereto as ANNEX
“H” and “I” are copies of Certificate of Births of
Melinda and Ramon, marked respectively;

10. This petition is being filed for the purpose of

correcting erroneous entries in the Certificate of Live
Birth of LUCIA DE CASTRO CARANDANG with
Registry No. 11 as to her date of birth, from
“DECEMBER 13, 1967” to “DECEMBER 3, 1968”

11. Petitioner is an indigent client of the Public Attorney’s

Office. As such, she is exempt from the payment of
docket and other legal fees pursuant to Republic Act
No. 9406, Section 16-D which states that:

"SEC. 16-D. Exemption from Fees and Costs of the

Suit. - The clients of the PAO shall exempt from
payment of docket and other fees incidental to
instituting an action in court and other quasi-
judicial bodies, as an original proceeding or on
appeal. xxx”

Attached herewith and made an integral part hereof as

ANNEXES “J” and “K” are the Certificates of
Indigency issued by Barangay Maugat East, Padre
Garcia, Batangas, and issued by the Office of the
Municipal Social Welfare and Development,
Municipality of Padre Garcia.

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 EVIDENCE FOR THE PETITIONER

The Petitioner will present the following pieces of evidence:

1. Annex “A”- Certificate of Live Birth of Lucia De Castro

Carandang issued by the Philippine Statistics Authority with
LCR No. 11;

2. Annex “B”- Certificate of Live Birth of Lucia De Castro

Carandangssued by the Local Civil Registrar of Padre
Garcia, Batangas

3. Annex “C”- Certificate of Baptism issued by the Holy

Family Parish

4. Annex “D”- Palagiang Talaan ng Mag-aaral sa Sekundarya

issued by Sto. Rosario High School, Alupay, Rosario,
Batangas

5. Annex “E”- Voter’s Identification Card issued by the

Commission on Elections, Padre Garcia, Batangas with VIN
1020-0055B-LO36820000

6. Annex “F”- SSS Identification Card issued by the Social

Security System Corporation, with number 33-3130500-2

7. Annex “G”- Certificate of Marriage of Santos Belgar and

Lucia de Castro Carandang-Belgar

8. Annex “H”- Certificate of Live Birth of Melinda de Castro

Carandang issued by the Philippine Statistics Authority with
LCR No. 979;

9. Annex “I”- Certificate of Live Birth of Ramon de Castro

Carandang issued by the Philippine Statistics Authority with
LCR No.;

10. Annex “J”- Certificate of Indigency issued by Brgy.

Maugat East, Padre Garcia; and

11. Annex “K”- Certificate of Indigency issued by Municipal

Social Welfare & Development Office of Padre Garcia,
Batangas.

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 WITNESSES FOR THE PETITIONER AND
SUMMARY OF THEIR RESPECTIVE TESTIMONIES

The Petitioner will present the following witnesses:

1. The Petitioner, LUCIA CARANDANG BELGAR, will

testify that she is the Petitioner in this case. She will present
her Certificate of Live Birth, with Registry No. 11 from the
Philippine Statistics Authority and the Local Civil Registrar
of Padre Garcia, Batangas.

She will identify this Petition to prove its existence and that
she is the one who filed the same before the Honorable
Court.

Moreover, she will present various documents to prove that

her true and correct date of birth is DECEMBER 3, 1968 and
not December 13, 1967. These documents are the following:
(1) Certificate of Baptism, (2) Palagiang Talaan ng Mag-
aaral sa Sekundarya issued by Sto Rosario High School (3)
Voter’s ID, (4) SSS ID and (5) Marriage Certificate.

She will likewise present the Certificate of Live Births of her

two older siblings to prove that she is the third born child of
her parents. She will likewise testify on other matters
pertinent to this Petition.

2. MELINDA DE CASTRO CARANDANG, will testify that

she is the eldest sibling of petitioner and that the petitioner
is the third born child of their parents and that the
petitioner was actually born on December 3, 1968 and not
on December 13, 1967.

She will present her Certificate of Live Birth and that of her
brother Ramon de Castro Carandang. She will likewise
testify on other matters pertinent to this Petition.

PRAYER

WHEREFORE, in view of the foregoing premises, it is most

respectfully prayed of this Honorable Court:

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 1. To notify the Local Civil Registrar of Padre Garcia,
Batangas and the Philippine Statistics Authority as to
the pendency of this petition; and

2. After due notice and hearing, that this petition be

granted ordering the Local Civil Registrar of Padre
Garcia, Batangas and the Philippine Statistics
Authority to correct the erroneous entry of the date of
birth in the Certificate of Live Birth of LUCIA DE
CASTRO CARANDANG with Registry Number 11 as
to her date of birth from “DECEMBER 13, 1967” to
“DECEMBER 3, 1968”.

Other reliefs just and equitable under the premises are likewise
prayed for.

Rosario, Batangas, August 24, 2022.

PUBLIC ATTORNEY’S OFFICE

Department of Justice
Rosario District Office
Double K Shell Station Bldg., Brgy. Masaya,
Rosario, Batangas

By:

RIO THERESE E. TOLENTINO-DELA PEÑA

Public Attorney II
MCLE Compliance No: VI-0019786 valid until 4/14/22
IBP Lifetime No. 016457, Batangas Chapter
Roll No. 64723

Noted by:

MICHAEL M. ARADA
OIC/Public Attorney II
MCLE Compliance No: VI-0010933
IBP Lifetime No. 018659, Quezon City Chapter
Roll No. 52107

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REPUBLIC OF THE PHILIPPINES )
MUNICIPALITY OF ROSARIO )
PROVINCE OF BATANGAS ) S.C.

VERIFICATION AND
CERTIFICATE OF NON-FORUM SHOPPING

I, LUCIA CARANDANG BELGAR, of legal age, married,

Filipino, resident of Brgy. Maugat East, Padre Garcia, Batangas after
having been sworn to in accordance with law, do hereby depose and
say:

1. That I am the petitioner in the above-entitled case;

2. That I have caused the preparation of the foregoing

petition and have read and understood the same and
all the allegations contained therein are true and
correct according to my personal knowledge based on
authentic documents;

3. That I have not therefore commenced any action or

proceeding involving the same issues in the Supreme
Court, the Court of Appeals, or other tribunal or agency
and that to the best of my knowledge, no such action or
proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or any other
tribunal or agency; and

4. That if I should learn that a similar action or

proceeding has been filed or is pending before the
Supreme Court, the Court of Appeals, or any division
thereof, or any other tribunal or agency, I undertake to
inform the Honorable Court of that fact within (5) days
from notice thereof.

IN WITNESS WHEREOF, I have hereunto set my hand to attest

the truthfulness of the foregoing this August 24, 2022 at Rosario,
Batangas.

LUCIA CARANDANG BELGAR

Affiant
SUBSCRIBED AND SWORN to before me this August 24, 2022
at Rosario, Batangas. Affiant personally appeared and exhibited to me
her Voter’s ID with VIN 1020-0055B-L0368LCB20000.

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Copy furnished:

OFFICE OF THE PROVINCIAL PROSECUTOR

Hall of Justice
Rosario, Batangas

OFFICE OF THE SOLICITOR GENERAL

134 Amorsolo St., Legaspi Village
Makati City
1229 Metro Manila
Registry Receipt No. __________________
Date __________________

PHILIPPINE STATISTICS AUTHORITY

PSA Complex, East Ave.
Diliman, Quezon City
1101 Metro Manila
Registry Receipt No. __________________
Date __________________

OFFICE OF THE LOCAL CIVIL REGISTRAR

Municipal Hall Building
Poblacion, Padre Garcia
Batangas
Registry Receipt No. __________________
Date __________________

PROOF/JUSTIFICATION OF SERVICE

Copy of this petition was served to the Office of the Solicitor

General, Philippine Statistics Authority, Office of the Local Civil
Registrar at the address stated above by registered mail with a return
card due to distance, time, and manpower constraints. However, a
copy of this petition was personally served to the Office of the
Provincial Prosecutor, Hall of Justice, Rosario, Batangas.

RIO THERESE E. TOLENTINO-DELA PEÑA