G.R. No. 127936 - Panado vs. Court of Appeals

The petitioner, originally named Haw Liong, is a 47-year-old married employee of the Leyte Asia Trading Company.
He has been a resident of Tacloban City for over 20 years.
He came to the Philippines in 1925 and has since been involved in various personal and business dealings.

Being commonly addressed as Alfonso by his Filipino friends.
The desire to adopt his father’s surname, Placido Lantin, which he finds more culturally appropriate.
A wish to conform with Filipino customs and traditions, especially as he is set to become a Filipino citizen.

His petition was filed before the Court of First Instance of Leyte, where he testified in support of his desire to change his name.

The petitioner testified that he had no legal impediments and that, in the event of any case against him under his old name, he was willing to appear and answer.
His testimony relied mainly on his personal narrative regarding the name usage by friends and associates.
Contradictory practices were noted:

In his business dealings, he consistently signed as Haw Liong.
His landing certificate and other official records still bear the name Haw Liong.

During cross-examination, it was revealed that the use of the name Alfonso emerged only during the Japanese occupation when asked by Filipino acquaintances, rather than a long-established identity.

The Court of First Instance granted the petitioner’s request to change his name.
The government, invoking the established doctrine regarding name changes, appealed the decision.
The case then reached a higher court, which reviewed the legitimacy and sufficiency of the petitioner’s reasons under precedent.

Whether the petitioner demonstrated a proper or compelling reason to change his name, considering the State’s interest in maintaining accurate identification.
Whether the petitioner’s reliance on personal and sentimental testimony, along with customary usage among friends, is sufficient to override the official name recorded since birth.
Whether the evidence presented, particularly his longstanding use of the name Haw Liong in business and official documents, negates his claim of having been known as Alfonso Lantin.
Whether the petition aligns with the legal requirement that a change of name is a privilege subject to stringent standards, as established in precedents like Ong Peng Oan vs. Republic.