G.R. No. L-8035 - Ong Peng Oan vs. Republic

The petitioner, Ong Peng Oan, is a Chinaman, aged 45, married, and a businessman residing at 507 Gelinos Street, Sampaloc, Manila.
He filed a petition to change his name to Vicente Chan Bon Lay, asserting that since 1946 he has been better known in both social and business circles by that name.

The petitioner claimed that he had consistently used the name Vicente Chan Bon Lay ever since his arrival in the Philippines in 1922.
He argued that the change of name is justified on the grounds that it reflects the name by which he is commonly recognized.

Documents attached to the petition revealed inconsistencies in the petitioner’s use of names:

A certificate issued by Justice of the Peace Geronimo J. Garcia of Navotas, Rizal, recorded the petitioner under the name Ong Pin Can for a conviction under Article 195 of the Revised Penal Code, along with a fine of ₱10.00 dated April 2, 1952.
A decision by Judge Conrado Barrios recorded his name as Ong Peng Oan alias Vicente Chan in connection with a conviction for violating section 2698 (related to sections 1111 and 1115, paragraph 6, of the Revised Administrative Code), with a fine of ₱20.

These discrepancies suggest that the petitioner has not been consistently using the name Vicente Chan Bon Lay as claimed, displaying instead a pattern of adopting different names possibly at his convenience.

The petitioner had been convicted twice for offenses (both gambling-related), which raised concerns about his intentions in seeking a name change.
The existence of these criminal records casts doubt on his claim and suggests an attempt to obscure or distance himself from an unsavory past.

The petitioner’s inconsistent use of names undermined his claim of using Vicente Chan Bon Lay continuously.
His criminal record made it likely that he intended to use the name change to hide his true identity.

The denial was supported by the reasoning that a name change is a privilege, not a right, especially when the petitioner has a history of using different names and has pending criminal implications.

Whether the petitioner’s consistent use of a different name (Vicente Chan Bon Lay) in social and business circles constitutes proper and reasonable cause for a legal change of name.
Whether the existence of multiple identities and discrepancies in his records, coupled with a criminal record, warrant the denial of his petition to change his name.
Whether the State’s interest in preserving the integrity and consistency of personal identification outweighs the petitioner’s claim of common usage of an alternative name.