G.R. No. 250520 - Santos vs. Republic

Francis Luigi G. Santos was born on January 9, 1992 in Quezon City as “Francis Luigi Guzman,” to Lovely Maria T. Guzman (mother) and Jose Marie Bautista Jr. (a.k.a. Bong Revilla Jr.) (biological father), who were not married. His birth certificate listed his father as “unknown.”
On April 24, 1996, Bong Revilla Jr. executed an Affidavit of Acknowledgment recognizing petitioner as his son.

In 1999, Lovely Guzman married Patrick Joseph P. Santos, who legally adopted petitioner in 2001, changing his name to “Francis Luigi G. Santos.”
Although raised under the surname Santos, petitioner grew close to his biological father’s family and began using the screen name “Luigi Revilla” upon entering show business, prompting him to seek an official name change to “Francis Luigi G. Revilla.”

On June 19, 2017, the Regional Trial Court (RTC) Branch 225, Quezon City found the petition sufficient in form, ordered publication, and invited government opposition. The Office of the Solicitor General (OSG) opposed, arguing lack of compelling reason.
On April 30, 2018, the RTC denied the petition, holding that (a) change of name is a privilege requiring compelling reasons, (b) adoption severs ties with biological parents and binds the adoptee to the adopter’s surname, and (c) petitioner’s use of “Revilla” was only a screen name.
The Court of Appeals (CA), First Division, in its August 28, 2019 Decision and November 20, 2019 Resolution, affirmed the RTC, holding further that petitioner should have availed of Rule 108 (correction of entries), and the petition was void for failure to implead both biological and adoptive fathers.

Whether petitioner properly invoked Rule 103 of the Rules of Court for change of name, or should have filed under Rule 108 for correction of entries.
Whether petitioner presented any compelling or reasonable cause justifying the change of surname from “Santos” to “Revilla.”