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THIRD DIVISION
[ G.R. No. 205218, February 10, 2020 ]
REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE SPECIAL
COMMITTEE ON NATURALIZATION (SCN), PETITIONERS, VS.
WINSTON BRIAN CHIA LAO AND CHRISTOPHER TROY CHIA LAO,
RESPONDENTS.
[G.R. No. 207075, February 10, 2020]
REPUBLIC OF THE PHILIPPINES, REPRESENTED BY THE SPECIAL
COMMITTEE ON NATURALIZATION (SCN), PETITIONERS, V. JON
NICHOLAS CHIA LAO, RESPONDENT.
DECISION
LEONEN, J.:
The birth certificate, more than a historical record of one's birth, is a vital marker of
identity. Therefore, acts and events, though occurring after birth, may be annotated on
the birth certificate so long as they are consistent with a legal truth and a special law
provides for its effects.
This resolves two (2) consolidated Petitions for Review on Certiorari[1] directly filed
before this Court by the Republic of the Philippines, represented by the Special
Committee on Naturalization (SCN), raising pure questions of law. In G.R. No. 205218,
the Republic questions the Decision[2] of the Regional Trial Court, Branch 30, Manila
that allowed the change in the nationality of Winston Brian Chia Lao (Winston Brian)
and Christopher Troy Chia Lao's (Christopher Troy) parents as entered in their
respective Certificates of Live Birth. In G.R. No. 207075, the Republic questions the
Decision[3] of the Regional Trial Court, Branch 105, Quezon City that allowed the same
change in the nationality of the parents of Jon Nicholas Chia Lao (Jon Nicholas) as
entered in his Certificate of Live Birth.
On October 14, 1962, Lao Kian Ben and Chia Kong Liong married at the Our Lady of
Lourdes Sta. Teresita Parish, Quezon City.[4] They are the parents of Jon Nicholas, born
on November 22, 1966,[5] Winston Brian, born on December 3, 1968,[6] and
Christopher Troy, born on March 19, 1973.[7] In the respective Ce1iificates of Live Birth
of Jon Nicholas, Winston Brian, and Christopher Troy issued by the now defunct
National Statistics Office, the indicated nationality of both Lao Kian Ben, as father, and
Chia Kong Liong, as mother, is "Chinese."
Thereafter, Lao Kian Ben applied for naturalization as a Filipino citizen before the
Special Committee on Naturalization, pursuant to Letter of Instructions No. 270. The
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