G.R. No. L-20306 - IN RE: Jesus Ng Yao Siong vs. Republic

Jesus Ng Yao Siong, a Chinese resident of Dumaguete City, is known by several names including "Jesus Ng", "Jesus Uy Keng Lee", "Uy Keng Lee Jesus", "Keng Lee Uy", "Uy Keng Lee", and "Jesus Ng Yao Siong".
The petitioner asserted that the multiplicity of names had caused confusion in school records and public dealings, leading to unnecessary delay and embarrassment.

The petitioner sought to standardize his name by having all other names changed to "Keng Lee Uy".
The petition was filed with the Negros Oriental court to authorize the change of name pursuant to Article 376 of the Civil Code.
The petitioner’s objective was to simplify his identity and obviate the confusion arising from his various aliases.

Change of name is a judicial proceeding in rem and requires the publication of an order stating the purpose of the petition, and the date and place for the hearing, for three successive weeks in a newspaper of general circulation.
The publication must provide correct and precise information including the petitioner’s true name, the cause for the change, and the new name requested.
In this case, the order of publication was printed in "The Negros Times" with the title “In the matter of the change of name of Jesus Ng Yao Siong, Jesus Ng Yao Siong, petitioner.”
However, the petitioner’s true name as recorded in the civil register is “Jesus Ng”, not “Jesus Ng Yao Siong”, thereby causing a discrepancy in the publication.

The petitioner had used various aliases (as evidenced in his school records, income tax returns, and alien certificate of registration), none of which were authorized by a competent court or recognized as his official name.
Under Commonwealth Act 142 ("An act to regulate the use of aliases"), a person is prohibited from using unapproved aliases.
The petitioner’s sustained use of these different names was seen as a violation of this law, which carries penalties including imprisonment.

The title of the petition did not reflect the proper name ("Jesus Ng") recorded in the civil register, thereby indicating a failure to meet the requirement for accurate publication.
The inclusion and omission of aliases in the title and body of the petition raised doubts as to whether the publication could adequately inform the public and protect the interests of those who might be affected by the name change.

Whether the publication of the petition complied with the strict legal requirements including the inclusion of the petitioner’s true name and his aliases.
Whether the petitioner’s failure to correctly state his official name (recorded in the civil register) in the petition’s title is fatal to the jurisdiction of the court over the change of name proceeding.
Whether the petitioner’s claim of confusion arising from the use of multiple names constitutes a “proper and reasonable cause” justifying the change of name.
Whether allowing the change of name would inadvertently sanction the petitioner’s unlawful use of aliases in contravention of Commonwealth Act 142.