G.R. No. L-15811 - IN RE: Manuel vs. Republic

Juan Manuel, petitioner, along with his children—Alexander, Gloria, Jack, and Victor (all of legal age except Gloria, Jack, and Victor who are 20, 18, and 16 respectively)—filed a petition for change of name in the Court of First Instance of Pangasinan (Special Procedure No. 13791).
The petition was duly published in the Pangasinan Courier once a week for three consecutive weeks.
The oppositor, the Republic of the Philippines, filed an opposition based on certain procedural grounds.

Juan Manuel sought to change his name due to frequent confusion caused by the common occurrence of his name in his locality.
He also desired to adopt his putative father’s surname, changing his name from Juan Manuel to Juan M. Eaton.
His children similarly wished to change their surname from Manuel to Eaton, logically following their father’s intended change.
The petition alleged the desire to establish a clear identity, both to avoid confusion in addressing and to align with the surname of his alleged natural father, John Eaton.

At birth, Juan Manuel was baptized with his mother’s surname, Manuel, as he was born out of wedlock.
According to the Civil Code, a natural child may only use the father’s surname if he or she is acknowledged by both parents; if recognized by only one parent, the child must use that parent's surname (Art. 366; also Art. 282).
There was no evidence on record that John Eaton had duly acknowledged Juan Manuel.
Thus, the petition for the change of name, which would have allowed Juan Manuel to use his alleged father’s surname, raised questions of legal propriety under the new Civil Code.

Whether the petition for a change of name, which included adopting the alleged natural father’s surname, complied with the procedural requirements given in the published notice and the subsequent trial process.
Whether the publication and hearing process was sufficient to establish notice.

Whether Juan Manuel, an illegitimate child who lacked acknowledgment by his natural father, John Eaton, has the legal right to change his surname to that of his alleged father under the provisions of the New Civil Code (specifically Article 366).
Whether the legal principle enunciated in prior cases, such as Valencia vs. Rodriguez, applies given the effectivity of the new Civil Code with its specific requirements on surname usage.

Whether permitting Juan Manuel to adopt the father’s surname would automatically extend to his children’s rights to use the same surname in their respective petitions for change of name.
Whether any repugnance to the existing legal framework for surname usage might be implicated by granting such a petition.