Case Digest (G.R. No. 117209) Core Legal Reasoning Model
Facts:
In March 1994, spouses Van Munson y Navarro and Regina Munson y Andrade filed a petition for adoption before the Regional Trial Court (RTC), Branch 158, Pasig City, to adopt a minor named Kevin Earl Bartolome Moran. Alongside the adoption petition, they simultaneously sought to change the minor’s first name to Aaron Joseph, the name given during baptism and used by the family since the child came under the care of the respondents in 1993. The petitioner, Republic of the Philippines, opposed the inclusion of the change of name request in the adoption petition, arguing that adoption and change of name are two distinct proceedings under different laws and rules and should be pursued separately. At the hearing, the RTC approved the adoption and allowed the change of the minor’s first name. The petitioner appealed, contending the RTC acted beyond its jurisdiction by granting the name change in the same proceeding without proper cause and failure to observe procedural requirements fo
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Case Digest (G.R. No. 117209) Expanded Legal Reasoning Model
Facts:
- Filing of Petition for Adoption and Change of Name
- On March 10, 1994, private respondents Spouses Van Munson y Navarro and Regina Munson y Andrade filed a petition to adopt the minor Kevin Earl Bartolome Moran.
- The petition properly alleged jurisdictional facts, qualifications and fitness of the adopters, and circumstances justifying adoption under Rule 99 of the Rules of Court.
- The petition also prayed for the change of the minor’s first name from Kevin Earl Bartolome Moran to Aaron Joseph, the name he was baptized with and had been called by family and friends since May 6, 1993, when he arrived at private respondents' residence.
- Opposition by Republic of the Philippines
- At the April 18, 1994 hearing and in a May 3, 1995 formal opposition, petitioner opposed the inclusion of change of name prayer in the adoption petition.
- Petitioner argued that adoption and change of name are distinct special proceedings requiring separate petitions with their respective substantive and procedural requirements.
- Petitioner maintained that allowing the change of the minor’s first name in the adoption petition was an excess of jurisdiction.
- Regional Trial Court’s Order
- The RTC, Regional Trial Court, Branch 158, Pasig City, approved the adoption of Kevin Earl Bartolome Moran by the private respondents.
- It also allowed the change of name from Kevin Earl Bartolome Moran to Aaron Joseph Munson y Andrade.
- The court recognized that minor was freed from legal obligations to natural parents and shall be known by the new name and surname upon finality of the adoption decree.
- The court noted publication of the name change along with the adoption petition, and found no prejudice or fraud in the change of name.
- No challenge was made to private respondents' fitness to adopt or validity of the adoption decree.
- Findings on Petitioners’ Qualifications and Compliance
- Trial court found that the private respondents met all qualifications under the law (Family Code Art. 183, 185), Child and Youth Welfare Code, and procedural requirements of Rule 99, Rules of Court.
- A comprehensive Social Case Study by DSWD endorsed the legitimacy and welfare of the adoption and attested to the suitability of private respondents as adoptive parents.
Issues:
- Whether the RTC erred in granting the prayer for the change of the given or proper first name of the minor adoptee in the petition for adoption.
- Whether there existed lawful grounds for the change of the first name of the adopted minor from Kevin Earl Bartolome to Aaron Joseph.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)