Title
In the matter of the petition of Juan Ching Ing King to change his name to Juan Manuel vs. Republic
Case
G.R. No. L-8301
Decision Date
Apr 28, 1956
Illegitimate son seeks name change to maternal surname; SC affirms decision, ruling oral testimony sufficient to establish filiation under Civil Code.
A

Case Digest (G.R. No. 156888)

Facts:

  • Petitioner's Background: Juan Ching Ing King filed a petition to change his name to Juan Manuel. He claimed to be the illegitimate son of Maria Manuel, a Filipino citizen, and Enrique Ching Ing King, who died in Lubao, Pampanga, on April 15, 1953.
  • Reason for Name Change: The petitioner sought to change his name because he was often mistaken for a Chinese due to his surname. As an illegitimate child, he believed it was more appropriate to use his maternal surname, especially after his father's death.
  • Compliance with Legal Requirements: The petitioner complied with the required publication of his petition.
  • Appellant's Argument: The Government (appellant) argued that the testimony of the petitioner and his mother, Maria Manuel, was insufficient to prove his filiation. They contended that corroborative documentary evidence, such as a birth certificate or baptismal certificate, should have been presented. They also argued that the court should have required further investigation by the fiscal or other government authorities.

Issues:

  • Whether the testimony of the petitioner and his mother, without corroborative documentary evidence, was sufficient to establish his filiation and justify the change of name.
  • Whether the court erred in granting the petition for a name change based on the evidence presented.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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