Case Summary (G.R. No. L-15811)
Allegations and Background
In their petition, the Manuel family sought to change their surname due to practical reasons stemming from confusion caused by multiple individuals sharing the name "Juan Manuel" in their locality. Additionally, Juan Manuel expressed a desire to adopt the surname Eaton, as he was born out of wedlock to John Eaton and Maria Arachea Manuel, and had used his mother's surname in his baptism. The petitioners collectively sought to change their surnames to Eaton to reflect this desire.
Procedural History
The petition for the name change was duly published over three weeks in the Pangasinan Courier, followed by opposition from the Solicitor General based on procedural grounds. Although only the petitioners presented evidence during the trial, the court ultimately granted the name change, leading to an appeal by the Republic.
Legal Basis for Name Change
The legal framework for assessing the change of name is articulated in the Civil Code, particularly Article 366, which stipulates that a natural child can use the surname of the father only if acknowledged by both parents. In cases of recognition by just one parent, the child may only use that parent's surname. In this instance, there was no textually confirmed acknowledgment from John Eaton, which played a critical role in the resolution of the case.
Court's Findings and Conclusion
The court highlighted that the request for a name change by Juan Manuel to Juan M. Eaton should have been denied on the basis that he lacked proper acknowledgment from his father. Despite recognizing the practical issues regarding his current name, the legal restriction from Article 366 of the Civil Code disallowed the use of Eaton without acknowledged legitimacy. The same rationale extended to Juan Manuel's children, nullifying their requested name changes as well.
Resolution and Motion for Reconsideration
In a subsequent resolution, the court reiterated its decision denying the name changes. The petitioners contended that a precedent, Valencia v. Rodriguez, permitted unacknowledged natural children to take their father’s surname, but the court clarified that the relevant laws had changed with the enactment of the new Civil Cod
...continue readingCase Syllabus (G.R. No. L-15811)
Case Background
- The case involves a petition for change of name filed by Juan Manuel and his children, Alexander, Gloria, Jack, and Victor, all bearing the surname Manuel.
- The petition was submitted to the Court of First Instance of Pangasinan, registered as Special Proceedings No. 13791.
- Juan Manuel, the father, sought to change his name due to commonality with others in his municipality, causing confusion.
- Another reason for the name change was Juan Manuel's desire to adopt his biological father's surname, John Eaton, who was American, in light of his illegitimate birth.
Petition Details
- Juan Manuel is the father of the petitioners, with the children being Alexander (20), Gloria (18), Jack (16), and Victor (16), all residing in Lingayen, Pangasinan.
- The petitioners have been bona fide residents of their municipality since birth.
- The desired changes include:
- Juan Manuel's name to be changed to John M. Eaton.
- Each child's surname to change from Manuel to Eaton, reflecting their father's name.
- The petition requested the publication of the hearing order in the Pangasinan Courier, which was duly executed.
Procedural History
- The Solicitor General opposed the petition based on procedural gro