Case Digest (G.R. No. 97906)
Facts:
- The case involves the Republic of the Philippines as the petitioner seeking to overturn a decision by the Court of Appeals.
- The Court of Appeals had affirmed a lower court's ruling that granted Maximo Wong's petition to change his name to Maximo Alcala, Jr.
- Maximo Wong was originally named Maximo Alcala, Jr. before being adopted by the spouses Hoong Wong and Concepcion Ty Wong, both naturalized Filipinos, on September 9, 1967.
- The adoption was done with the consent of his biological parents, Maximo Alcala, Sr. and Segundina Y. Alcala.
- Upon reaching the age of twenty-two and being married, Maximo Wong filed a petition to revert to his original surname.
- He cited embarrassment and social isolation due to his Chinese surname, which he claimed hampered his business and social life in his predominantly Muslim community.
- The trial court granted his petition on July 2, 1986.
- The decision was upheld by the Court of Appeals despite opposition from the Solicitor General.
- The Solicitor General argued that the reasons provided were insufficient and that the change would violate Articles 341 and 365 of the Civil Code, which mandate that an adopted child should use the surname of the adopter.
Issue:
- (Unlock)
Ruling:
- The Supreme Court denied the petition of the Republic and affirmed the decision of the Court of Appeals in toto.
- This allowed M...(Unlock)
Ratio:
- The Supreme Court emphasized the legal significance of a person's name for identification purposes.
- A name change is a privilege granted upon showing valid reasons.
- The Court found that the reasons provided by Maximo Wong, including embarrassment, social isolation, and the negative impact on his business and social life due to his Chinese surname, were valid and sufficient.
- The Court noted that his adoptive mother consented to the name change, indicating no prejudice to her or the st...continue reading
Case Digest (G.R. No. 97906)
Facts:
The case involves the Republic of the Philippines as the petitioner and Maximo Wong as the private respondent. The events leading to this case began when Maximo Wong, born as Maximo Alcala, Jr., was adopted at the age of two and a half by Hoong Wong and Concepcion Ty Wong, both naturalized Filipinos, following a court order issued on September 9, 1967. Maximo Wong was the legitimate son of Maximo Alcala, Sr. and Segundina Y. Alcala. After his adoption, he was raised by his adoptive parents, who were childless for fifteen years before adopting him and his sister.
Years later, at the age of twenty-two, Maximo Wong, now married and a junior Engineering student at Notre Dame University in Cotabato City, filed a petition to change his name back to Maximo Alcala, Jr. He argued that his surname, Wong, caused him embarrassment and social isolation within his Muslim community, as it suggested a Chinese ancestry, which was contrary to his identity as a Muslim Filipino. He claimed that this name affected his business and social life negatively. The trial court granted his petition on July 2, 1986, after determining that all jurisdictional requirements were met. The Republic, through the Solicitor General, appealed this decision to the Court of Appeals, which affirmed the trial court's ruling. Consequently, the Republic filed a petition for review on certiora...