Republic v. Boquiren

Summary

This case involves siblings seeking to correct their birth certificates by canceling legitimation annotations and replacing them with acknowledgment of paternity. The Supreme Court reversed lower court decisions, ruling that Rule 108 proceedings cannot be used to collaterally attack legitimacy or determine marriage validity. The Court held that legitimation can only be impugned by prejudiced parties in direct proceedings, not by the legitimated children themselves who benefit from the status. The decision reinforces the principle that substantial corrections involving legitimacy and filiation require proper direct actions, not mere civil registry corrections. The Court distinguished cases where no marriage actually existed from situations involving void marriages, emphasizing procedural safeguards in family law matters.