Case Digest (G.R. No. 97906) Core Legal Reasoning Model
Facts:
The case involves Maximo Wong, the private respondent, originally named Maximo Alcala, Jr., legitimate son of Maximo Alcala, Sr., and Segundina Y. Alcala. At about two and a half years old, Maximo was adopted by the late Hoong Wong and Concepcion Ty Wong, both naturalized Filipinos residing in Cotabato City. This adoption was with the consent of his natural parents and by court order dated September 9, 1967 (Special Case No. 593). The Wongs, unable to have biological children after fifteen years of marriage, raised Maximo and his sister Margaret as their own, with Maximo adopting the surname Wong pursuant to the law.
Upon reaching 22 years old, married, and a junior engineering student, Maximo Wong filed a petition to change his name back to Maximo Alcala, Jr., asserting that using the surname Wong caused embarrassment and isolation among his Muslim Filipino community in Cotabato, as it suggested Chinese ancestry. He claimed this resulted in ridicule and hampered his business a
Case Digest (G.R. No. 97906) Expanded Legal Reasoning Model
Facts:
- Parties and procedural posture
- Private respondent Maximo Wong, born Maximo Alcala, Jr., was adopted by spouses Hoong Wong and Concepcion Ty Wong in Special Case No. 593 by court order dated September 9, 1967.
- The petition for the change of name from Maximo Wong back to Maximo Alcala, Jr. was granted by the Regional Trial Court (RTC), Branch XIV, Cotabato City, on July 2, 1986 (Special Proceeding No. 189).
- The Court of Appeals affirmed the RTC decision, maintaining the validity of the name change petition.
- The Republic of the Philippines, through the Solicitor General, filed a petition for review on certiorari to set aside the CA decision.
- Background of private respondent and reasons for name change
- Maximo Wong is the legitimate son of Maximo Alcala, Sr., and Segundina Y. Alcala. He was adopted at age two and a half by the Wongs, who were childless.
- After adoption, private respondent carried the surname "Wong."
- Private respondent, a Muslim Filipino living in a Muslim community, experienced embarrassment and isolation due to the Chinese surname "Wong," which misrepresented his true ethnicity and religion.
- He claimed social ridicule and business impediments caused by his surname, affecting his personal and commercial relationships. He desired to revert to his original surname "Alcala, Jr." to avoid such difficulties.
- The adoptive mother, Concepcion Ty Wong, consented to the petition for change of name, asserting no prejudice to the legal adoption or familial relations.
- Position of the petitioner (Republic of the Philippines)
- The Solicitor General opposed the petition, asserting that:
- The allegations of ridicule and isolation were unsubstantiated.
- Reverting to the original surname amounted to ingratitude to the adoptive parents, especially the deceased adoptive father.
- The change violated Articles 341 and 365 of the Civil Code, mandating that an adopted child shall bear the adopter’s surname, thus threatening the legal relationship created by adoption.
Issues:
- Whether the reasons given by private respondent for the change of name are valid, sufficient, and proper to warrant the granting of the petition for change of name.
- Whether private respondent’s reversion to his original surname violates the legal mandates under Articles 341 and 365 of the Civil Code and related laws on the use of the adopter’s surname by the adopted child.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)