### Facts:
In 1996, Maria Rosilyn Telin Delantar filed a complaint against her father, Simplicio Delantar, for child abuse, particularly prostitution. As a result, Simplicio was jailed, and the Department of Social Welfare and Development (DSWD) obtained a court order to become Rosilyn’s guardian due to her mother Librada Ceruila’s unknown whereabouts. In February 1997, the Ceruilas sought to annul Rosilyn’s birth certificate, alleging it was falsified – including incorrect parental data and birth details. They obtained a court ruling in their favor in April 1997, which was challenged by Rosilyn (through the DSWD) in the Court of Appeals (CA) in July 1997, arguing lack of due process and jurisdiction. The CA voided the RTC’s decision in 1999, emphasizing the absence of requisite notifications and parties, including Rosilyn and the DSWD.
### Issues:
1. Whether the action to annul and cancel the birth certificate constitutes a special proceeding or an ordinary civil action.
2. Compliance with procedural requirements under Rule 108 of the Rules of Court.
3. The CA’s authority in a petition for annulment of judgment based on lack of jurisdiction.
### Court’s Decision:
The Supreme Court treated the petition as a review on certiorari and held the following:
1. The petition filed by the Ceruilas, alleging falsification of Rosilyn’s birth certificate, falls under Rule 108 of the Rules of Court as a special proceeding due to its nature of seeking the cancellation or correction of entries in the Civil Registry.
2. The Ceruilas failed to comply with Rule 108 requirements, notably the mandatory participation of all parties affected by the cancellation of the birth certificate, including Rosilyn herself and the DSWD as her guardian.
3. The CA’s authority was correctly limited to ruling on procedural issues, particularly the lack of jurisdiction and due process in the original RTC decision, without delving into the merits of the birth certificate annulment itself.
### Doctrine:
1. Rule 108 of the Rules of Court mandates that all parties with an interest affected by the cancellation or correction of an entry in the Civil Registry must be made parties to the proceeding.
2. Due process requires not just publication but the actual notification of all interested parties, including those whose status would be directly impacted by the case outcome.
3. An annulment of judgment petition under Rule 47 focuses solely on grounds of extrinsic fraud and lack of jurisdiction, not on the merits of the original case.
### Class Notes:
– Special Proceedings vs. Ordinary Civil Actions: Understand the nature of the case to determine the applicable procedural rules.
– Rule 108 of the Rules of Court: Memorize the requirement that all interested parties must be included in cancellation or correction of civil registry entries cases.
– Due Process in Judicial Proceedings: Note the importance of notifying all parties potentially affected by the court’s decision to ensure fairness and legality.
– Rule 47’s Scope and Limitations: Recognize the grounds and effects of filing a petition for annulment of judgment for lack of jurisdiction or due to extrinsic fraud.
### Historical Background:
This case highlights the intersection of civil registry accuracy, child welfare, and procedural due diligence within the Philippine judicial system. It emerged amidst the backdrop of a high-profile criminal case involving minor Rosilyn Delantar, bringing attention to the complexities of legal guardianship, birth records’ integrity, and the critical role of procedural due process in ensuring justice for all involved parties.
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