Republic of the Philippines

REGIONAL TRIAL COURT

7th Judicial Region, Branch _____
Cebu City, Cebu

IN THE MATTER OF CHANGE OF NAME OF

ANGELIQUE GRACE CALAMBA FROM
ANGELIQUE GRACE CALAMBA
MONDRAGON TO ANGELIQUE GRACE
CALAMBA AND CORRECTION OF ENTRIES
IN DATE AND PLACE OF MARRIAGE OF
PARENTS TO NOT APPLICABLE AND
CANCELLATION OF LATE REGISTRATION IN
LOCAL CIVIL REGISTRAR OF CEBU CITY

ANGELIQUE GRACE CALAMBA,

Petitioner,

-versus-

OFFICE OF THE CITY CIVIL

REGISTRAROF CEBU CITY and
CARCAR CITY and ANTONIO
JABINES MONDRAGON,
Respondents.
x----------------------------------------------------x

PETITION
COMES NOW, Petitioner by the Undersigned Counsel, and to this
Honorable Court, most respectfully states that:

THE CASE

1. The instant case is a petition for correction of entries in the

petitioner’s certificate of live birth seeking to correct the erroneous
surname and entry in the fact of marriage of the petitioner’s biological
parents, seeking to cancel a late registration with the Office of the Civil
Registrar of Cebu City;

STATEMENT OF JURISDICTION

2. Under Section 1, Rule 108, it is provided that any person interested

in the correction or cancellation of entries recorded in the civil register,
may file a verified petition with the Regional Trial Court of the province
where the corresponding civil registry is located;

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 THE PARTIES

3. Petitioner is of legal age, Filipino, single and a resident of Ramos,

Cebu City while respondent is a public agency with office address at Office
of the City Local Civil Registrar, City Health Building, General Maxilom,
Cebu City, and the Local Civil Registrar of Carcar is also a public agency
in Carcar, Cebu where it may be served with summons and other processes
of this Honorable Court;

THE FACTS

4. Petitioner was born on January 6, 1988 at Margarita Birthing Center,

Carcar, Cebu to parents MIRASOL CUABO CALAMBA and
ANTONIO JABINES MONDRAGON;

5. Facts of her birth were registered with the Respondent Civil

Registrar of Carcar, but through inadvertence, the name of the child entered
therein was ANGELIQUE GRACE CALAMBA MONDRAGON,
instead of the correct one which should have been ANGELIQUE GRACE
CALAMBA. Attached herewith is the Certificate of Live Birth of the
Petitioner issued by the National Statistics Office (NSO) under Registry
Number 88-0112 bearing multiple erroneous entries marked as Annex “A”
and forms an integral part of this petition;

6. The parents of the Petitioner were never married and had no

communication for almost twenty-eight (28) years already. Moreover,
Petitioner was never acknowledged by her father as his daughter, attached
herewith as Annex “B” is the Certificate of No Marriage between
MIRASOL CUABO CALAMBA and ANTONIO JABINES
MONDRAGON issued by the NSO and Annex “C” is the Affidavit of
Mirasol Cuabo Calamba, Petitioner’s mother;

7. The true and correct entries should be the full name of the petitioner
from ANGELIQUE GRACE CALAMBA MONDRAGON TO
ANGELIQUE GRACE CALAMBA, the place and date of marriage of
parents of the petitioner from DECEMBER 28, 1987 to NOT
APPLICABLE based on the Petitioner’s Certificate of Baptism, hereto
attached as Annex “D,” Voter’s Registration Records hereto attached as
Annex “E”, her Diploma hereto attached as Annex “F” and all forms an
integral part of this Petition;

8. Also sometime in 1992, Petitioner’s mother caused the late

registration of her birth before the Civil Registrar of Cebu City,
registered under Registry No. 1992-1208 and is hereto attached as Annex
“H” and forms an integral part of this petition;

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 9. To avoid conflict and further discrepancies, Petitioner seeks the
cancellation of the same;

10.Petitioner has been continuously using the name ANGELIQUE

GRACE CALAMBA since birth up to the present and she never used at
any given time the name ANGELIQUE GRACE CALAMBA
MONDRAGON in all her dealings, personally in school, and in
community and she is well known by such name as ANGELIQUE
GRACE CALAMBA MONDRAGON in her community or elsewhere.
For this purpose, an “Affidavit of Two Disinterested Persons” is attached
hereto and is made an integral part hereof as Annex “G”;

11. Petitioner had been unaware of the incorrect entries in her birth
records for a considerable length of time, until lately, when she secured a
copy of her Certificate of Live Birth from the National Statistics Office that
she discovered the foregoing errors or discrepancies.

PRAYER

WHEREFORE, in view of the foregoing, it is respectfully prayed

of this Honorable Court to issue an order DIRECTING the Office of the
Civil Registrar of Carcar TO CORRECT the entries of the subject
Certificate of Live Birth in the following manner:

1. Name of the Petitioner from ANGELIQUE GRACE CALAMBA

MONDRAGON TO ANGELIQUE GRACE CALAMBA.

2. Date and Place of Marriage from DECEMBER 28, 1987, CARCAR,

CEBU to NOT APPLICABLE.

It is further prayed that the Honorable Court issue an Order directing

the NSO TO ISSUE in favor of the petitioner a new and correct birth
certificate bearing such correct name and to change to not applicable the
date and place of marriage of parents in lieu of the erroneous ones to
directing the Office of the Civil Registrar of Cebu City to CANCEL her
late registration.

Other reliefs deemed legal, just and equitable in the premises are
likewise prayed for.

Cebu City, Philippines March 15, 2016.

RESPECTFULLY SUBMITTED.

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 YAP DEGAMO MERINO SALAZAR
PARADO LAW OFFICE
Counsel for the Petitioner
G/F GMC Plaza Building, Legaspi
Extension corner M.J. Cuenco St., Cebu City,
Philippines
Tel No. (032) 4956587; Cel No. 09174773172
By:

SHENNA JANE PARADO

Roll of Attorney No. 50072
PTR OR No. 78312; January 6, 2016; Cebu City
IBP No. 99675; January 6, 2016; Cebu City
E-mail: paradoshenna@gmail.com
MCLE Compliance No. IV-0009

JESSICA YAP
Roll of Attorney No. 50792
PTR OR No. 78945; January 6, 2016; Cebu City
IBP No. 99879; January 6, 2016; Cebu City
E-mail: jessicayap@gmail.com
MCLE Compliance No. IV-0010

Copy furnished:

Solicitor General
Office of the Solicitor General
134 Amorsolo St., Legaspi Village
Makati City, Philippines

The Office of the Local Civil Registrar

Carcar City, Cebu, Philippines

The Office of the Local Civil Registrar

Cebu City, Philippines
City Health Building, General Maxilom, Cebu City

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 VERIFICATION & AFFIDAVIT OF NON-FORUM SHOPPING
I, Angelique Grace Calamba, of legal age, Filipino, single and with a mailing
address at Ramos, Cebu City Philippines, after having been duly sworn to in accordance
with law do hereby depose and state, that:

1. I have caused the preparation of the foregoing Petition;

2. I have read the allegations therein and verify that the same are true and
correct based on my own personal knowledge and/or on authentic records;
3. I have not commenced any action or filed any claim involving the same or
similar issues to any other court, tribunal or quasi-judicial agency, including
the Court of Appeals and Supreme Court, or any division thereof, and to the
best of my knowledge, no such other action or claim is pending therein. If
should learn hereafter that the same or similar action or claim has been filed
or is pending, I shall report that fact within five (5) days from such
knowledge to this Honourable Court;
4. I am executing this affidavit in order to attest to the truth of the foregoing;

IN WITNESS WHEREOF, I have hereunto affixed my signature this 14th day

of March, 2016 at the City of Cebu, Philippines.

ANGELIQUE GRACE CALAMBA

Affiant

SUBSCRIBED AND SWORN TO before me this 15th day of March 2016 at

the City of Cebu, Philippines. Affiant exhibited to me his
__________________________ numbered as _________________________ issued by
_____________________ on _______________________ expiring on
__________________________.

ATTY. EUGENE V. AMORES

Notary Public
Notarial Commission Until December 31, 2018

Doc. No.: ____________

Page No.:_____________
Book No.:____________
Series of 2016

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