Case Summary (G.R. No. 127936)
Case Background
Haw Liong filed a petition before the Court of First Instance of Leyte seeking to change his name to Alfonso Lantin. The petitioner, a 47-year-old married man residing in Tacloban City for over 20 years, expressed his desire to adopt a Filipino name in anticipation of becoming a Filipino citizen. He testified to his longstanding association with the name Alfonso, which his Filipino friends used to call him, linking it to his father’s name, Placido Lantin.
Court’s Initial Ruling
The lower court granted Haw Liong’s request to change his name to Alfonso Lantin. However, this decision was met with opposition from the government, which appealed the ruling, arguing the necessity for a compelling reason for such a change.
Legal Principles on Name Change
The Supreme Court reiterated that the State has a vested interest in the names individuals carry, primarily for identification purposes. Changing one’s name is seen as a privilege rather than an inherent right. Jurisprudence outlines that one must present a reasonable cause to justify the change of name, which includes but is not limited to the following instances: an inappropriate or dishonorable name, a change coinciding with a change of status, or the avoidance of confusion.
Assessment of Petitioner’s Justifications
Upon review, the Supreme Court found that Haw Liong did not provide sufficient evidence of a compelling reason beyond his desire to adopt the name Alfonso Lantin. His justification—that he is called Alfonso by Filipino friends and wishes to honor his father’s name—lacked substantiation when juxtaposed against the legal requirement that a name change must fulfill specific conditions.
Analysis of Evidence
The Court observed that, despite Haw Liong's claims, he had consistently engaged in business under his original name and had only adopted 'Alfonso' during social interactions prompted by friends during the Japanese occupation. The petitioner's testimony did not sufficiently counterbalance the official designation of his name established at birth, as evidenced by his landing certific
...continue readingCase Syllabus (G.R. No. 127936)
Case Background
- The case is recorded as 123 Phil. 537, G.R. No. L-21194, decided on April 29, 1966.
- The petitioner, Haw Liong, sought to change his name to Alfonso Lantin through a petition filed in the Court of First Instance of Leyte.
- The petitioner provided personal background information, stating he is 47 years old, married, and employed at the Leyte Asia Trading Company.
- He has resided in Tacloban City for over 20 years and expressed a desire to adopt a name that aligns with Filipino customs and his father's name, Placido Lantin.
Petitioner's Testimony
- Haw Liong testified that he is commonly called Alfonso by his Filipino friends, which influenced his desire to change his name.
- He stated that he wishes to have a Filipino name as he plans to become a Filipino citizen.
- He arrived in the Philippines in 1925 and has been known as Alfonso by his friends since the Japanese occupation when they asked for his name.
- He confirmed that there are no pending legal cases against him under his current name, Haw Liong, and expressed willingness to respond to any future cases under that name.
Court of First Instance Decision
- The Court of First Instance allowed the name change from Haw Liong t