TAN V.

TROCIO in the said lot in favor of her two nieces, Irene Colinco
to one-half (1/2) and Purificacion Arbolario to the other
Facts: half. Purificacion Arbolario was then allowed to take
Complainant is a married woman. She declares possession of a portion of the disputed parcel until her
that sometime in April, 1971, at about 8:30 PM,after death sometime in 1984 or 1985.
classes were dismissed, Trocio, who is the legal
counsel of the school, overpowered herinside the office
and, against her will, succeeded in having carnal
knowledge of her. As a result,she begot a son on 5 Respondents Irene Colinco, Ruth Colinco,
February 1972 whom she named and registered as Orpha Colinco, and Goldelina Colinco, believing
Jewel Tan. Butrespondent vehemently denies that he themselves to be the only surviving heirs of Anselmo
had sexually assaulted the Complainant. Baloyo and Macaria Lirazan, executed a ‘Declaration of
Heirship and Partition Agreement’, dated May 8, 1987
Issue: Whether or not Jewel is a legitimate child of where they adjudicated upon themselves their
Trocio proportionate or ideal shares: Irene Colinco, to one-half
(1/2); while the surviving daughters of her (Irene’s) late
Held: No. The testimonies of Complainant and witness brother Antonio, namely Ruth, Orpha, and Goldelina
Marilou Pangandaman, another maid, to show unusual Colinco, to share in equal, ideal proportions to the
closeness between Respondent and Jewel, like playing remaining half (1/2).
with him and giving him toys, are not convincing enough On October 2, 1987, the Colincos filed a case
to prove paternity, as Complainant would want us to against Spouses Rosalita Rodriguez Salhay and Carlito
believe. The same must be said Exhibits A, A1, B and Salhay, seeking to recover possession of a portion of
B1, which are pictures of Jewel and Respondent the aforesaid lot occupied by respondent spouses
showing allegedly their physical likeness to each other. (‘Salhays’ hereinafter) since 1970. The Salhays alleged
Such evidence is inconclusive to prove paternity, and in their defense that they have been the lawful lessees
much less would it prove violation of Complainant’s of the late Purificacion Arbolario since 1971 up to 1978;
person and honor. and that said spouses allegedly purchased the disputed
portion of Lot from the deceased lessor sometime in
September 1978.
ARBOLARIO V. CA
On May 9, 1988 before the case was tried the
Facts: Arbolarios and spouses Carlito Salhay and Rosalita
The original owners of the controverted lot, Rodriguez Salhay (all respondents in the case) filed
spouses Anselmo Baloyo and Macaria Lirazan, had 5 another case ‘[f]or Cancellation of Title with Damages’.
children. Everyone mentioned is dead. The first child, The Arbolarios, joined by the Salhays, contend that the
Agueda Colinco, was survived by her two children, ‘Declaration of Heirship and Partition Agreement’
namely, Antonio Colinco and Irene Colinco executed by the Colincos was defective and thus
(respondent); Antonio Colinco predeceased his three voidable as they (Arbolarios) were excluded therein.
daughters, respondents Ruth, Orpha, and Goldelina, all The Arbolarios claim that they succeeded intestate to
surnamed Colinco. The second child, Catalina Baloyo, the inheritance of their alleged half-sister, Purificacion
was married to Juan Arbolario and their union was Arbolario; and, as forced heirs, they should be included
blessed with the birth of only one child, Purificacion in the distribution of the aforesaid lot.
Arbolario, who, in 1985, died a spinster and without
issue. Juan Arbolario, consorted with another woman by
the name of Francisca Malvas and from this Relevant Issue:
cohabitation petitioners Voltaire Arbolario, Lucena
(1) W/N Arbolarios are illegitimate children
Arbolario Taala, Fe Arbolario, Exaltacion Arbolario, and
Carlos Arbolario (referred to hereinafter as ‘Arbolarios’)
Held:
were born. All the foregoing petitioners were born well
before the year 1951. (1) YES, they are illegitimate.** There is no solid
basis for the argument of petitioners that Juan
Arbolario’s marriage to Francisca Malvas was
In 1946, the third child, Eduardo Baloyo, sold valid. It does not follow that just because his first
his entire interest in the lot to his sister, Agueda (first wife has died, a man is already conclusively
child), by virtue of a notarized document. In 1951, a married to the woman who bore his children. A
notarized declaration of heirship was executed by and marriage certificate or other generally accepted
between Agueda, Catalina, Gaudencia, and their proof is necessary to establish the marriage as
brothers Eduardo and Julian, who extrajudicially an undisputable fact. Since they failed to prove
declared themselves to be the only heirs of the late
the fact (or even the presumption) of marriage
spouses Anselmo Baloyo and Macaria Lirazan. The
between their parents, Juan Arbolario and
fourth child, Gaudencia Baloyo, conveyed her interest
Francisca Malvas; hence, they cannot invoke a
 presumption of legitimacy in their favor. CABATANIA V CA
Paternity or filiation, or the lack of it, is a
Facts:
relationship that must be judicially
established. Version of Florencia Regodos Controversy
stems from a petition for recognition and support filed
NOTES: by Florencia Regodos in behalf of her minor son, private
respondent Camelo Regodos. Camelo Regodos (same
name as the petitioner) was born on September 9,
 LOWER COURT RULINGS: 1982. Florencia testified that she was the one
o RTC: Arbolarios were the brothers and supporting her child Florencia recounted that after her
the sisters of the deceased Purificacion husband left in 1981, he went to Escalante, Negros
Arbolario, while the Colincos were her Occidental to look for work and was eventually hired as
cousins and nieces. The Colincos Camelo‘s household help On January 2, 1982, Camelo
brought her to Bacolod City where they checked in at
could not inherit from her, because she
the Visayan Motel and had sexual intercourse. Camelo
had half-brothers and half-sisters (CC,
promised to support her if she got pregnant Florencia
Article 1009). Their 1987 Declaration
claimed that she discovered she was carrying Camelo‘s
of Heirship and Partition Agreement child 27 days after their sexual encounter On suspicion
was made in bad faith, because they that Florencia was pregnant, Camelo‘s wife sent her
knew all along the existence of, and home. But Camelo instead brought her to Singcang,
their relationship with, the Arbolarios. Bacolod City where he rented a house for her. On
The Salhays, on the other hand, had no September 9, 1982, assisted by a hilot in her aunts
document to prove their acquisition and house in Tiglawigan, Cadiz City, she gave birth to her
possession of a portion of the disputed child, private respondent Camelo Regodos. Meanwhile
lot. the version of Camelo Cabatania, basically he says that
o CA: Arbolarios are illegitimate. the father of the child is Florencia‘s husband and when
Illegitimate children are barred by they had sex, she was already pregnant Petitioner
Article 992 of the Civil Code from refused support, denying the alleged paternity He
inheriting intestate from the legitimate denied going to Bacolod City with her and checking in
at the Visayan Motel. He vehemently denied having sex
children and relatives of their father or
with her on January 2, 1982 and renting a house for her
mother. As the illegitimate siblings of
in Singcang, Bacolod City.
the late Purificacion Arbolario,
petitioners cannot conveniently
undermine the legal limitations by
Issue: Can the court compel petitioner Camelo
insisting that they were treated as half-
Cabatania to acknowledge Regodos as his illegitimate
brothers and half-sisters by the
son and to give support to him?
deceased.
 **(other reasons for illegitimacy, seemed Held:
less important): A review of the 1951
A certificate of Live Birth purportedly identifying
Declaration reveals that the year of Catalina’s
the putative father is not competent evidence of
death was intercalated. The first two numbers paternity when there is no showing that the putative
(1 and 9) and the last digit (3) are legible; but father had a hand in the preparation of said certificate.
the third digit has been written over to make it
look like a “0.” Further, the paragraph quoted The local civil registrar has no authority to record the
by petitioners should show a chronological paternity of an illegitimate child on the information of a
progression in the heirs’ years of death: third person.
Agueda died in 1940 and Eduardo in 1947. The fact that Florencia’s husband is living and
Hence, if Catalina had indeed died in 1903, why there is a valid subsisting marriage between them gives
then was her name written after Agueda’s and rise to the presumption that a child born within that
not before it? Moreover, the document, being marriage is legitimate even though the mother may
in Spanish, requires an official translation. We have declared against its legitimacy or may have been
cannot readily accept the English translation sentenced as an adulteress. (Article 167 of the Family
proffered by petitioners, since respondents did Code)
not agree to its correctness. Besides, it
In this age of genetic profiling and
consisted of only a paragraph of the whole deoxyribonucleic acid (DNA) analysis, the extremely
document. subjective test of physical resemblance or similarity of
features will not suffice as evidence to prove paternity
and filiation before the courts of law.
 support to Joanna, he alleged that he is not the father
Concepcion vs. CA of Joanna, hence this petition. RTC rendered a decision
GR No. 123450, August 31, 2005 and declared the minor to be the illegitimate child of Ong
with Jinky Diaz, and ordering him to support the child
FACTS: until she reaches the age of majority. Ong opposed the
CA’s order to directing the Estate and Joanne Rodgin
Gerardo Concepcion, the petitioner, and Ma. Theresa Diaz for DNA analysis for determining the paternity of
Almonte, private respondent, were married in the minor Joanne.
December 1989, and begotten a child named Jose
Gerardo in December 1990. The husband filed on During the pendency of the case, Rogelion Died. The
December 1991, a petition to have his marriage Estate filed a motion for reconsideration with the Court
annulled on the ground of bigamy since the wife married of Appeals. They contended that a dead person cannot
a certain Mario Gopiao sometime in December 1980, be subject to testing. CA justified that “DNA paternity
whom according to the husband was still alive and living testing, as current jurisprudence affirms, would be the
in Loyola Heights, QC. Trial court ruled that the son was most reliable and effective method of settling the
an illegitimate child and the custody was awarded to the present paternity dispute.
wife while Gerardo was granted visitation
rights. Theresa argued that there was nothing in the law
granting “visitation rights in favor of the putative father ISSUE:
of an illegitimate child”. She further wanted to have the
surname of the son changed from “Concepcion to Whether or not DNA analysis can still be done even if
Almonte”, her maiden name, since an illegitimate child the person is whose DNA is the subject is dead.
should use his mother’s surname. After the requested
oral argument, trial court reversed its ruling and held the RULING:
son to be not the son of Gerardo but of Mario. Hence,
the child was a legitimate child of Theresa and
Yes.The court held that the death of Rogelio does not
Mario.
ipso facto negate the application of DNA analysis so
long as there exist, suitable biological samples of his
HELD:
DNA. The New Rules on DNA Evidence permits the
manner of DNA testing by using biological samples–
Considering that Theresa’s marriage with Gerardo was
organic material originating from the person’s body, for
void ab initio, the latter never became the former’s
example, blood, saliva, other body fluids, tissues, hair,
husband and never acquired any right to impugn the
bones, even inorganic materials- that is susceptible to
legitimacy of the child. Theresa’s contention was to
DNA testing. In case proof of filiation or paternity would
have his son be declared as not the legitimate child of
be unlikely to adequately found or would be hard to get,
her and Mario but her illegitimate child with Gerardo. In
DNA testing, which examines genetic codes found from
this case, the mother has no right to disavow a child
body cells of the illegitimate child and any physical
because maternity is never uncertain. Hence, she is not
remains of the long dead parent could be resorted to.
permitted by law to question the son’s
legitimacy. Under Article 167 of the Family Code, “the
child shall be considered legitimate although the mother
may have declared against its legitimacy or may have
been sentenced as an adulteress”. Having the best DE JESUS VS. ESTATE OF JUAN DIZON
interest of the child in mind, the presumption of his G.R. No. 142877, October 2, 2001
legitimacy was upheld by the Court. As a legitimate
child, the son shall have the right to bear the surnames FACTS:
of Mario and Theresa, in conformity with the provisions
of Civil Code on surnames. Gerardo cannot then
Danilo B. de Jesus and Carolina Aves de Jesus got
impose his surname to be used by the child, since in the
eyes of the law, the child is not related to him in any married in August 1964. It was during this marriage that
way. Jacqueline A. de Jesus and Jinkie Christie A. de
Jesus, herein petitioners, were born. In a notarized
document, dated June 7, 1991, Juan
G. Dizon acknowledged Jacqueline and Jinkie de Jesus
ESTATE OF ROGELIO ONG V. DIAZ as being his own illegitimate children
by Carolina Aves de Jesus. Juan died intestate in
FACTS: March 1992, leaving behind considerable assets
consisting of shares of stock in
Minor Diaz filed a complaint before the Regional Trial various corporations and some real property. It was on
Court for compulsory recognition with prayer for support the strength of his notarized acknowledgement that
against Rogelio Ong, she was represented by her petitioners filed a complaint for “Partition with Inventory
mother Jinky. Before the case, Jinky married a certain and Accounting” of the Dizon estate with the RTC.
Hasegawa Katsuo, Japanese. That same year, Jinky
met Rogelio, they fell in love. The next year, Rogelio and
Jinky cohabited. After four years, Joanna was born, Respondent, the surviving spouse and legitimate
Rogelio recognized Joanna as his, however, that same children of the decedent, including the corporations of
year, Rogelio abandoned them and stopped giving which the deceased was a stockholder, sought
the dismissal of the case, arguing that the complaint,
even while denominated as being one for partition, maintained that she and the deceased were legally
would nevertheless call for altering the status of married but living separately for more than 10 years and
petitioners from being the legitimate children of the that they cohabited from 1965 until the death of the
spouses Danilo and Carolina de Jesus to instead be the deceased. On the other hand, one of the chidren of the
illegitimate children of Carolina de Jesus deceased stated that her mom and the deceased were
and deceased Juan Dizon. legally married and that her parents were not separated
legally or in fact.
ISSUE:
ISSUE: WON the petitioner can impugn his own
legitimacy to be able to claim from the estate of the
Whether or not petitioners are illegitimate children of
deceased.
decedent Juan Dizon entitled to inherit from him
HELD:
RULING:
Impugning the legitimacy of the child is a strictly
No. A scrutiny of the records would show that petitioners personal right of the husband, or in exceptional cases,
were born during the valid marriage of their parents his heirs for the reason that he was the one directly
Danilo and Carolina. The certificates of birth confronted with the scandal and ridicule which the
also identified Danilo de Jesus as their father. There is infidelity of his wife produced and he should be the one
a presumption in law that children born in wedlock are to decide whether to conceal that infidelity or expose it
legitimate. This presumption indeed becomes in view of the moral and economic interest
conclusive in the absence of proof that there is physical involved. Hence, it was then settled that the legitimacy
impossibility of access between the spouses during the of the child can only be impugned in a direct action
first 120 days of the 300 days which immediately brought for that purpose, by the proper parties and
precedes the birth of the child due to (a) the physical within the period limited by law.
incapacity of the husband to have sexual intercourse
with his wife; (b) the fact the husband and wife are living Furthermore, the court held that there was no clear,
separately in such a way that sexual intercourse is not competent and positive evidence presented by the
possible; or (c) serious illness of the husband, which petitioner that his alleged father had admitted or
absolutely prevents sexual intercourse. Quite recognized his paternity.
remarkably, upon the expiration of the periods set forth
in Article 170, and in proper cases Article 171,of the
Family Code (which took effect on August 3, 1988), the Babiera v.Catotal
action to impugn the legitimacy of a child would no G.R. No. 138493, June 15, 2000
longer be legally feasible and the status conferred by
the presumption becomes fixed and unassailable.
FACTS:
In an attempt to establish their illegitimate filiation to the
Presentacion B. Catotal filed a petition for the
late Juan, petitioners, in effect, would impugn their
cancellation of the entry of birth of Teofista Babiera.
legitimate status as being children of Danilo
and Carolina de Jesus. This step cannot be aptly done From the petition filed, Presentacion asserted the
because the law itself establishes the legitimacy of following:
children conceived or born during the marriage of the
parents. The presumption of legitimacy fixes a civil a. that she was the only surviving child of the late spouses
status for the child born in wedlock, and only the father, Eugenio Babiera and Hermogena Cariñosa, who died
or in exceptional instances the latter’s heirs, on May 26, 1996 and July 6, 1990 respectively;
can contest in an appropriate action the legitimacy of b. that on September 20, 1996 a baby girl was delivered
a child born to his wife. Thus, it is only when the by “hilot” in the house of spouses Eugenio and
legitimacy of a child has been successfully impugned Hermogena Babiera and without the knowledge of said
that the paternity of the husband can be rejected. spouses, Flora Guinto, the mother of the child and a
housemaid of spouses Eugenio and Hermogena
Liyao vs. Liyao Babiera, caused the registration/recording of
the facts of birth of her child, by simulating that she was
GR No. 138961, March 7, 2002
the child of the spouses Eugenio, then 65 years old and
FACTS: Hermogena, then 54 years old, and made Hermogena
Babiera appear as the mother by forging her
William Liyao Jr., the illegitimate son of the deceased, signature that petitioner, then 15 years old, saw with her
as represented by her mother (Corazon), filed a petition own eyes and personally
c. witnessed Flora Guinto give birth to Teofista Guinto, in
ordering Juanita Tanhoti-Liyao, Pearl L. Tan, Tita L. Tan
their house, assisted by “hilot”;
and Linda Liyao to recognize and acknowledge the
d. that the birth certificate of Teofista Guinto is void ab
former as a compulsory heir of the deceased and to be
initio, as it was totally a simulated birth, signature of
entitled to all successional rights. Liyao Jr. was in
continuous possession and enjoyment of the status as informant forged, and it contained false
the child of the deceased having been recognized and
acknowledged as such child by the decedent during his Teofista filed a motion to dismiss on the grounds that
lifetime. There were two sides of the story. Corazon “the petition states no cause of action, it being an attack
on the legitimacy of the respondent as the child of survived only by her husband, Martin Guerrero, and
the spouses Eugenio Babiera and herein petitioners. Petitioners’ father, Hermogenes, died
HermogenaCariñosaBabiera; that plaintiff has no on October 3, 1973, hence they seek to inherit from
legal capacity to file the instant petition pursuant to Teodora Dezoller Guerrero by right of representation.
Article 171 of the Family Code; and finally that the The records reveal that upon the death of Teodora
instant petition is barred by prescription in accordance Dezoller Guerrero, her surviving spouse executed an
with Article 170 of the Family Code. Affidavit of Extrajudicial Settlement adjudicating unto
himself, allegedly as sole heir, the land in dispute.
ISSUE: Martin sold the lot to herein private respondent Teodora
Domingo and thereafter.
Whether or not a certificate of live birth is sufficient
to establish the legitimacy of a child regardless of the Martin Guerrero died. Subsequently, herein petitioners
fact that the same is obtained by fraud or that it filed an action for reconveyance claiming that they are
contained some irregularities entitled to inherit one-half of the property in question by
right of representation. Tedoro Domingo however,
RULING: attacks the legitimacy of Hermogenes.

No. The present case alleged and showed that

Hermogena did not give birth to petitioner. The prayer Issue: Whether or not a third person, not the father nor
was not to declare that petitioner was an illegitimate an heir, may attack the legitimacy of Hermogenes
child of Hermogena, but to establish that the former was
not the latter’s child at all. The action did not impugn
petitioner’s filiation to Spouses Eugenio and Held: NO. the private respondent is not the proper party
Hermogena Babiera, because there was no blood to impugn the legitimacy of herein petitioners. There is
relation to impugn in the first place. no presumption of the law more firmly established and
founded on sounder morality and more convincing
reason than the presumption that children born in
While it is true that an official document such as wedlock are legitimate. And well settled is the rule that
petitioner’s Birth Certificate enjoys the presumption of the issue of legitimacy cannot be attacked collaterally.
regularity, the specific facts attendant in the case, as
well as the totality of the evidence presented during
trial, sufficiently negate such presumption. First, there Only the husband can contest the legitimacy of a child
were already irregularities regarding the born to his wife. He is the one directly confronted with
Birth Certificate itself. It was not signed by the local civil the scandal and ridicule which the infidelity of his wife
registrar. More important, the Court of Appeals produces; and he should decide whether to conceal that
observed that the mother’s signature therein was infidelity or expose it, in view of the moral and economic
different from her signatures in other interest involved. It is only in exceptional cases that his
documents presented during the trial. heir are allowed to contest such legitimacy. Outside of
these cases, none — even his heirs — can impugn
The circumstances surrounding the birth of petitioner legitimacy; that would amount to an insult to his
show that Hermogena was not the former’s real mother. memory.
There was no evidence of Hermogena’s pregnancy,
such as medical records and doctor’s prescriptions,
other than the Birth Certificate itself. Moreover, at the TSPS FIDEL VS CA
time of her supposed birth, Hermogena was already 54
years old. Even if it were possible for her to have given BRAZA VS CITY CIVIL REGISTRAR
birth at such a late age, it was highly suspicious that she
did so in her own home, when her advanced age Petitioner Ma. Cristina’s husband, Pablo died
necessitated proper medical care normally available on April 15, 2002 in a vehicular accident in Indonesia.
only in a hospital. The most significant piece During the wake following the repatriation of his remains
of evidence, however, was the deposition of
to the Philippines, respondent Lucille Titular began
Hermogena Babiera which stated that she did not give
birth to petitioner, and that the latter was neither hers introducing her co-respondent minor Patrick Alvin
nor her husband Eugenio’s. Titular Braza (Patrick) as her and Pablo's son.
Petitioner thereupon made inquiries with the Local Civil
TISON VS CA Registrar of Himamaylan City, Negros Occidental. On
the annotation of Patrick’s birth certificate reflects
Patrick as having been acknowleged by Pablo (or
Facts: The petitioners Corazon Tison and Rene
Dezoller are niece and nephew of the deceased Tedora Pablito) as son on January 13, 1997, that he was
Dezoller Guerrero, who appears to be the sister of their legitimated by virtue of subsequent marriage of parents
father Hermogenes Dezoller . The present action for on April 22, 1998 at Manila, and that he shall be known
reconveyance involves a parcel of land with a house as Patrick Titular Braza.
and apartment which was originally owned by the
spouses Martin Guerrero and Teodora Dezoller Ma. Cristina likewise obtained a copy of a
Guerrero. It. Teodora Dezoller Guerrero died on March marriage contract showing that Pablo and Lucille were
5, 1983 without any ascendant or descendant, and was
married on April 22, 1998, drawing her and her co- parties are impleaded and due process is properly
petitioners (her three legitimate children with Pablo) to observed.
file on December 23, 2005 before the Regional Trial
Court of Himamaylan City, Negros Occidental a The petitioners’ cause of action is actually to
petition to correct the entries in the birth record of seek the declaration of Pablo and Lucille’s marriage as
Patrick in the Local Civil Register. void for being bigamous and impugn Patrick’s
legitimacy, which causes of action are governed not by
Contending that Patrick could not have been Rule 108 but by A.M. No. 02-11-10-SC which took effect
legitimated by the supposed marriage between Lucille on March 15, 2003, and Art. 171 of the Family Code,
and Pablo, said marriage being bigamous on account of respectively, hence, the petition should be filed in a
the valid and subsisting marriage between Ma. Cristina Family Court as expressly provided in said Code.
and Pablo, petitioners prayed for (1) the correction of
the entries in Patrick's birth record with respect to his It is well to emphasize that, doctrinally, validity
legitimation, the name of the father and his of marriages as well as legitimacy and filiation can be
acknowledgment, and the use of the last name "Braza"; questioned only in a direct action seasonably filed by
2) a directive to Leon, Cecilia and Lucille, all surnamed the proper party, and not through collateral attack such
Titular, as guardians of the minor Patrick, to submit as the petition filed before the court a quo.
Parick to DNA testing to determine his paternity and
filiation; and 3) the declaration of nullity of the Petition Denied.
legitimation of Patrick as stated in his birth certificate
and, for this purpose, the declaration of the marriage of
Lucille and Pablo as bigamous.

TC dismissed the petition, holding that in a

special proceeding for correction of entry, the court,
which is not acting as a family court under the Family
Code, has no jurisdiction over an action to annul the
marriage of Lucille and Pablo, impugn the legitimacy of
Patrick, and order Patrick to be subjected to a DNA test,
hence, the controversy should be ventilated in an
ordinary adversarial action.

MR was denied. Hence, this petition for review.

Issue: W/N the court a quo may pass upon the validity
of marriage and questions on legitimacy even in an
action to correct entries in the civil registrar. (WON
substantial errors, such as those sought to be corrected
in the present case, can be the subject of a petition
under Rule 108)

Held: NO. In a special proceeding for correction of entry

under Rule 108 (Cancellation or Correction of Entries in
the Original Registry), the trial court has no jurisdiction
to nullify marriages and rule on legitimacy and filiation.

Ratio:

Rule 108 of the Rules of Court vis a vis Article

412 of the Civil Code charts the procedure by which an
entry in the civil registry may be cancelled or corrected.
The proceeding contemplated therein may generally be
used only to correct clerical, spelling, typographical and
other innocuous errors in the civil registry. A clerical
error is one which is visible to the eyes or obvious to the
understanding; an error made by a clerk or a transcriber;
a mistake in copying or writing, or a harmless change
such as a correction of name that is clearly misspelled
or of a misstatement of the occupation of the parent.
Substantial or contentious alterations may be allowed
only in adversarial proceedings, in which all interested