Case Digest (G.R. No. L-4948) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Anacleto Ballaho Alanis III v. Court of Appeals, decided on January 30, 2023 under G.R. No. 216425, petitioner Anacleto Ballaho Alanis III, born to Mario Alanis y Cimafranca and Jarmila Imelda Ballaho y Al-Raschid, sought to change his registered name from “Anacleto Ballaho Alanis III” to “Abdulhamid Ballaho.” He alleged that since childhood he has been known by his mother’s maiden name “Ballaho” and the given name “Abdulhamid,” as reflected in his school records, diplomas, identification cards, driver’s license, and community tax certificate. The Regional Trial Court (RTC) of Zamboanga City, Branch 12, denied his petition on April 9, 2008, holding that he failed to prove any legal ground under Article 364 of the Civil Code and that granting the change would cause greater confusion and disregard his paternal surname in violation of the Family Code. Petitioner’s counsel, Atty. Johny Boy Dialo, was incapacitated after a shooting incident, resulting in a belated notice of appeal Case Digest (G.R. No. L-4948) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Proceedings and Parties
- Petitioner Anacleto Ballaho Alanis III filed a petition before the Regional Trial Court of Zamboanga City, Branch 12, seeking to change his name on his birth certificate from “Anacleto Ballaho Alanis III” to “Abdulhamid Ballaho.”
- The RTC issued an April 9, 2008 Order denying the petition for lack of legal grounds and a June 2, 2008 Order denying reconsideration.
- Petitioner’s Background and Evidence
- He was born to Mario Alanis y Cimafranca (father) and Jarmila Imelda Ballaho y Al-Raschid (mother). His official name was registered as Anacleto Ballaho Alanis III.
- He testified and presented school records, diplomas, IDs, license, and other documents showing he has used “Abdulhamid Ballaho” since childhood and is known by that name in his community.
- RTC’s Findings and Rationale
- The RTC held that mere long-time use of another name does not constitute a valid ground for change of name.
- It stressed that under Article 364 of the Civil Code and Article 174 of the Family Code, legitimate children shall principally use their father’s surname, and that changing it would cause more confusion and disregard paternal lineage.
- Appellate History
- Petitioner’s appeal to perfect the Record on Appeal was filed out of time, invoking his counsel’s excusable neglect due to a shooting incident; the RTC denied the late appeal.
- The Court of Appeals dismissed his certiorari petition for failure to show grounds to relax procedural rules and for lack of grave abuse of discretion.
Issues:
- Whether the petition should be dismissed for petitioner’s failure to show grave abuse of discretion by the Court of Appeals.
- Whether legitimate children have the right to use their mother’s surname as their surname.
- Whether petitioner established any recognized ground for changing his first and last name.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)