Case Summary (G.R. No. 231998)
Applicable Law and Nature of the Case
The decision rests on provisions found in the 1987 Philippine Constitution. The petition for change of name was initiated under Rule 45 of the Rules of Court, contesting previous decisions rendered by the Court of Appeals which disallowed Eric from changing the name registered on his birth certificate.
Legal Proceedings and Factual Background
On January 7, 2013, Eric filed his petition in which he claimed to have been born to Cheong Kiat, a Chinese national, and Melania Sibayan, a Filipino. Following the birth, his father secured a legal change of this surname to "Chua," which was also the name Eric had adopted and used in all his personal documentation. The case was heard in Special Proceeding Case No. 907 before the Regional Trial Court (RTC) in Balaoan, La Union.
Testimonies and Evidence Presented
During the RTC proceedings, Eric testified about the lack of access to his father’s birth certificate and how he had always used "Chua" for all credentials including baptismal and voter certification. His mother corroborated this assertion, explaining that it was an error in registration that incorrectly recorded his name. Witnesses from the community also affirmed that he was recognized as "Eric Chua."
Regional Trial Court's Ruling
On January 22, 2014, the RTC granted Eric’s petition, asserting the change of name was merely a correction of records. The RTC directed the Local Civil Registrar to amend Eric’s birth certificate accordingly.
Court of Appeals Ruling
The Republic, via the Office of the Solicitor General, appealed the RTC's decision. On November 7, 2016, the Court of Appeals reversed the RTC's ruling, asserting that Eric had not sufficiently proven his father's legal name change nor demonstrated clear prejudice from using his registered name, thus dismissing the petition for lack of factual basis.
Supreme Court's Findings
The Supreme Court concluded that the Court of Appeals erred in its assessment. It found the petition valid based not only on the claim regarding Eric's father’s name change but also on the fact that Eric had been using "Chua" consistently across various documents. The Court recognized several acceptable grounds for a name change, including the avoidance of confusion, which was applicable in this case due to Eric's established community identity as "Eric Chua."
Legal Basis for the Ruling
Referencing earlier jurisprudence, particularly Republic v. Coseteng-Magpayo, the Court affirmed that established usage and community re
...continue readingCase Syllabus (G.R. No. 231998)
Nature of the Case
- This case involves a Petition for Review on Certiorari under Rule 45 of the Rules of Court.
- The petitioner, Eric Sibayan Chua, is contesting the November 7, 2016 Decision and May 19, 2017 Resolution of the Court of Appeals (CA) in CA-G.R. CV No. 102624.
- The CA's rulings disallowed the petitioner from changing the name on his birth certificate from "Eric Sibayan Kiat" to "Eric Sibayan Chua."
The Facts
- On January 7, 2013, Eric filed a petition to change his surname from "Kiat" to "Chua."
- He claims to have been born on November 8, 1973, to a Chinese father, Cheong Kiat, and a Filipino mother, Melania Sibayan.
- Cheong purportedly secured a legal judgment allowing him to change his surname to "Chua" after Eric's birth.
- Eric has been using "Eric Sibayan Chua" in all his credentials and is known as "Eric Chua" in his community.
- The petition was filed in Special Proceeding Case No. 907 at the Regional Trial Court (RTC), Branch 34, in Balaoan, La Union.
- The RTC determined that the petition was sufficient in form and substance, leading to trial on May 21, 2013.
- Evidence presented included Eric's Certificate of Baptism, Voter Certification, Police Clearance, NBI Clearance, Passport, High School Diploma, and his children's birth certificates, all reflecting the name "Eric Sibayan Chua."
- Melania tes