G.R. No. L-62654-58 - People vs. Dagangon

Candido Uy, also known as Ricardo Uy, filed a petition for change of name on March 10, 1961, in the Court of First Instance of Pampanga.
He is a naturalized Filipino citizen, having taken his oath on October 9, 1959, and was born in 1933.
Petitioner has resided in San Fernando, Pampanga since birth and established his furniture business in 1961.
Although he bears the Chinese surname “Uy”, which is also common among native-born Filipinos, his name has caused confusion regarding his nationality.

The petitioner complained that his Chinese surname has led to mistaken identity, with him being frequently misidentified as a Chinese citizen.
This misidentification has resulted in personal embarrassment, disappointment, and negative repercussions in both social and business encounters.
Specific difficulties included:

Having to repeatedly explain his naturalized Filipino status in transactions, especially with government agencies.
Experiencing complications in joining civic organizations, such as the Lions Club, due to misidentification.

For his new surname, the petitioner chose “Baluyot”, in honor of former Secretary Sotero Baluyot.
Sotero Baluyot, who has maintained a long-standing relationship with the petitioner’s family since the pre-war period, even acted as the godfather to the petitioner’s father.
The petitioner obtained written consent from Baluyot (Exh. E) for the adopted name, which follows the accepted practice in the Philippines.

After fulfilling the requisite publication requirements, the court heard the petition.
The Republic, represented by the Assistant Provincial Fiscal, opposed the petition on the basis that the petitioner had not shown sufficient prejudice from the continued use of his present name.
Despite the opposition, on November 22, 1961, the trial court granted the petition.

Whether the petitioner established a “proper and reasonable cause” as required under Rule 103 of the Rules of Court for a change of name.
Whether his desire to change his surname from “Uy” to “Baluyot” is sincere and sufficiently supported by evidence to overcome the objection raised by the Republic regarding potential lack of prejudice.
Whether the alleged social and business prejudices due to the Chinese-sounding surname can justify the judicial grant of a name change.