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Republic of the Philippines

REGIONAL TRIAL COURT OF BOHOL


7th Judicial Region
BRANCH 47
City of Tagbilaran

IN THE MATTER OF THE PETITION FOR


CORRECTION OF THE YEAR OF BIRTH OF
LUCRECIO TORTOR DACULA
FROM 1951 TO 1949, AND HIS FIRST NAME
FROM LUCRESIO TO LUCRECIO IN HIS
CERTIFICATE OF LIVE BIRTH

Sp. Proc. No. 3516

LUCRECIO TORTOR DACULA


Petitioner.
X--------------------------/

FORMAL OFFER OF EXHIBITS

The Petitioner, by counsel, most respectfully formally offer the


following documentary exhibits in support of his prayer to the Honorable
Court that an order be issued directing the Office of the Civil Registrar in the
Municipality of Catigbian, Bohol, and the Civil Registrar General of the
Philippine Statistics Authority, to correct petitioner’s date of birth in his
Certificate of Live Birth from March 15, 1951 to March 15, 1949, and his
first name from Lucresio to Lucrecio:

1. Exhibit “A” - Verified Amended Petition for the Correction of Entries


in the Certificate of Live Birth, with a Certification of Non-
Forum Shopping, executed by petitioner LUCRECIO TORTOR
DACULA, and received by the Honorable Court on March 18, 2019.

Purpose: Exhibit “A” is formally offered to prove that:

a. Petitioner is currently a resident of Novaliches, Quezon City,


but he was born in Barangay Triple Union, Municipality of
Catigbian, Province of Bohol, on March 15, 1949. However,
due to distance and financial difficulties, petitioner’s birth was
not immediately registered in the Local Civil Registrar;

b. It was only on November 27, 1969 when petitioner’s birth was


registered. The month and date of his birth was registered as

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MARCH 15; however, the year was inadvertently written as
1951, instead of 1949 which is his true and correct year of birth;

c. Aside from the error in the year of birth, the spelling of


petitioner’s first name was written as “LUCRESIO” instead of
“LUCRECIO” which is the true intended spelling of his first
name and the spelling he has been using all his life;

d. In all public and official documents or records of petitioner


such as his Baptismal Certificate, School Transcript of Records,
Marriage Contract, Social Security System (SSS) identification
card, Professional Driver’s License, Senior Citizen
identification card, and Voter’s identification card, among
others, all showed his date of birth written as MARCH 15,
1949, and the spelling of his first name as “LUCRECIO”;

e. All members of petitioner’s family and friends know that his


true date of birth is MARCH 15, 1949 and his first name is
“LUCRECIO”, as attested to by two (2) close friends of
petitioner, Eugenio Silagan and Maria Andoy, in their Joint
Affidavit;

f. Petitioner has complied with all the requirements in filing this


petition, and has submitted his Barangay Clearance, Police
Clearance, NBI Clearance, and Court Clearances from MTC
and RTC;

g. Petitioner desires that an order be issued directing the Local


Civil Registrar of the Municipality of Catigbian, Province of
Bohol, and as well as the Civil Registrar General of the
Philippine Statistics Authority to correct petitioner’s date of
birth in his Certificate of Live Birth from MARCH 15, 1951 to
MARCH 15, 1949, and his first name from LUCRESIO to
LUCRECIO;

2. Exhibit “B” – Due Course Order dated March 18, 2019.

Purpose: Exhibit “B” is formally offered to prove that:

a. That the Honorable Court has found the petition sufficient in


form and substance;

b. That the Honorable Court directed for the publishing of the


Order once a week for three (3) consecutive weeks in a
newspaper of general circulation in the City of Tagbilaran and
Province of Bohol;

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c. That the Honorable Court directed for a copy of the Order,
together with the petition and all annexes, be furnished to the
Office of the Solicitor General, the Local Civil Registrar of
Catigbian, Bohol, the Philippine Statistics Authority (PSA),
Manila and the petitioner through counsel;

3. Exhibit “C” – Affidavit of Publication dated May 21, 2019 issued by


the Managing Editor of Bohol Sunday News, Ruth A. Boldo-
Manglay.

4. Exhibit “C-1” – Newspaper clipping showing the Order issued by the


court, and the dates it was published, April 7, 14, and 21, 2019.

Purpose: Exhibits “C” and “C-1” are formally offered to prove the
fact that the Order was duly published once a week for three
(3) consecutive weeks in BOHOL SUNDAY NEWS, a
newspaper of general circulation in the City of Tagbilaran and
Province of Bohol, during the following dates:

a. April 7, 2019
b. April 14, 2019
c. April 21, 2019.

5. Exhibit “D” – Authenticated Certificate of Live Birth issued by the


Philippine Statistics Authority (PSA).

6. Exhibit “E” – Certificate of Live Birth issued by the Office of the Local
Civil Registrar of Catigbian, Bohol.

Purpose: Exhibits “D” and “E” are formally offered to prove that:

a. Petitioner’s birth was duly registered at the Office of the Local


Civil Registrar of the Municipality of Catigbian, Bohol;

b. Petitioner’s Certificate of Live Birth is authenticated by the


Civil Registrar General of the Philippine Statistics Authority
(PSA); and

c. That in his Certificate of Live Birth, petitioner’s first name was


written as “LUCRESIO” and his date of birth was written as
MARCH 15, 1951;

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7. Exhibit “F” – Certificate of Baptism issued by the Immaculate
Conception Parish, Catigbian, Bohol.

8. Exhibit “G” – School Transcript of Records issued by the


Southwestern University in Cebu City.

Purpose: Exhibits “F” and “G” are formally offered to prove that:

a. Petitioner was baptized on April 3, 1949 at the Immaculate


Conception Parish, Catigbian, Bohol;

b. Petitioner finished his studies at Southwestern University in


Cebu City;

c. Both the Baptismal Certificate and School Transcript of


Records show petitioner’s name as LUCRECIO T.
DACULA, and date of birth as MARCH 15, 1949;

9. Exhibit “H” – Marriage Contract authenticated by the Philippine


Statistics Authority, with the name of petitioner written as
Lucrecio Dacula, date of marriage August 19, 1976, and the age of
petitioner at the time of marriage was written as “27” years old.

Purpose: Exhibit “H” is formally offered to prove that:

a. Petitioner contracted marriage with Ulpiana Pacot Alo in


San Mateo, Rizal on August 19, 1976;

b. Petitioner’s first name in the Marriage Contract was written


as “LUCRECIO”, and his age was written as “27” years old;

10. Exhibit “I” – Social Security System identification card with


number 03-3327772-0.

11. Exhibit “J” – Driver’s License issued by the Land Transportation


Office with License No. N02-69-005812.

12. Exhibit “K” – Senior Citizen identification card issued on June 5,


2009 by the Office for Senior Citizens Affairs, Quezon City,
with Control No. 111008.

13. Exhibit “L” – Voter’s identification card issued by the Commission


on Elections.

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Purpose: Exhibits “I”, “J”, “K”, and “L” are formally offered
to prove that:

a. Petitioner has secured valid identification cards


from different government offices/agencies such
as the Social Security System, Land Transportation
Office, Office of Senior Citizens Affairs, and
Commission on Elections, among others;

b. The records in all of the abovementioned


government offices/agencies show petitioner’s
name written as “LUCRECIO T. DACULA”, and his
date of birth written as “MARCH 15, 1949;

14. Exhibit “M” – Joint Affidavit of Two Disinterested Persons


executed by Eugenio Silagan and Maria Andoy, attesting to
the fact that petitioner’s name is Lucrecio T. Dacula and that
he was born on March 15, 1949.

Purpose: Exhibit “M” is formally offered to prove that


close friends and former neighbors of petitioner in
Catigbian, Bohol, who are familiar with his identity
and circumstances of his birth, attested that his true
and correct first name is “LUCRECIO”, and his date of
birth is “MARCH 15, 1949”;

15. Exhibit “N” – Clearance from the National Bureau of Investigation

16. Exhibit “O” – Barangay Clearance

17. Exhibit “P” – Police Clearance

18. Exhibit “Q” – Municipal Trial Court (MTC) Clearance

19. Exhibit “R” – Regional Trial Court (RTC) Clearance

Purpose: Exhibits “N”, “O”, “P”, “Q”, and “R” are formally
offered to prove that petitioner has complied with the
Order of the Honorable Court dated February 11,
2019 to secure and submit clearances from the
respective government offices.

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Original copies of EXHIBITS “A”, “B”, “C”, “C-1” and “M” are already
attached to the case records.

Original copies of EXHIBITS “D”, “E”, “F”, “H”, “N”, “O”, “P”, “Q”, and “R”
are attached herewith.

Original copies of EXHIBITS “G”, “I”, “J”, “K”, and “L” were already shown
to, and authenticated by, the Honorable Court. Machine copies are
already attached to the case records.

WHEREFORE, it is most respectfully prayed to the Honorable


Court that the foregoing documentary exhibits/annexes be admitted in
evidence for the petitioner for the purposes for which they are offered
and as part of the respective testimonies of witnesses LUCRECIO T.
DACULA and EFRAIM RACHO.

With the submission and the admission of the above documentary


exhibits, together with the testimonies of the witnesses as evidence for
the Petitioner, we rest our case.

RESPECTFULLY SUBMITTED.

_______________, Tagbilaran City, Bohol, Philippines.

ATTY. GERALDEE FRANCES M. CLOMA


Counsel for the Petitioner

c/o FCB Head Office Building, 0982 CPG North Ave.,


Taloto District, Tagbilaran City 6300, Bohol, Philippines
Tel. No. (038) 412-7310 local 4091
Roll No. 66794 : May 23, 2017
IBP No. 053304: October 24, 2018 for 2019
MCLE Compliance No. VI-0006642; February 23, 2018
PTR No. 0600406 : January 03, 2019/TIN: 239-218-809
CTC No. 19098800 issued on 01-04-2019 at Tagbilaran City
Mobile No. 09326019437

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Copy furnished by registered mail:

OFFICE OF THE SOLICITOR GENERAL


134 Amorsolo Street
Legaspi Village, Makati City, 1229

OFFICE OF THE PROVINCIAL PROSECUTOR


Hall of Justice, New Capitol Site
Tagbilaran City, Bohol 6300

OFFICE OF THE CITY PROSECUTOR


Hall of Justice, New Capitol Site
Tagbilaran City, Bohol 6300

EXPLANATION OF NON-PERSONAL SERVICE

The OFFICES of the SOLICITOR GENERAL, PROVINCIAL


PROSECUTOR, and CITY PROSECUTOR were sent a copy of this Formal
Offer of Exhibits by registered mail in lieu of personal delivery that
cannot be effected due to distance between offices and/or due to lack of
manpower.

GERALDEE FRANCES M. CLOMA

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