Case Summary (G.R. No. 160597)
Facts of the Case
The respondent, Roselie Eloisa Bringas Bolante, petitioned the Regional Trial Court for a change of name from her registered name, “Roselie Eloisa Bringas Bolante,” to “Maria Eloisa Bringas Bolante,” a name she had consistently used in her personal, academic, and professional life. The RTC initially found the petition sufficient in form and substance and scheduled hearings as mandated by law. Throughout the process, various documents supporting her claim were marked as evidence without objection from the Republic, represented by the Office of the Solicitor General.
Trial Court Proceedings
During the hearings, respondent provided testimony detailing her reasons for seeking a name change, citing the potential for confusion and her long-standing use of the name Maria Eloisa in various records and identification documents. Following multiple rescheduling of hearings due to initial publication errors, the trial court eventually declared its jurisdiction over the case and granted her petition on January 23, 2002. The court ordered the change of name to be recorded in the Civil Registry, emphasizing the merit of the petitioner’s request.
Appeal to the Court of Appeals
The Republic challenged the RTC's decision before the Court of Appeals, arguing issues related to the jurisdiction of the trial court and the sufficiency of evidence presented. The key points of contention were whether the respondent's compliance with publication requirements of Rule 103 was adequate to vest the RTC with jurisdiction, as well as whether her testimony, unsupported by other forms of evidence, was enough to prove that the name change was not for illicit purposes.
Jurisdictional Requirements
The Supreme Court noted that a change of name petition is governed by Sections 2 and 3 of Rule 103, which outline the necessary conditions for the filing and hearing of such petitions, including residency, the cause for the name change, and publication in a newspaper of general circulation. The Court affirmed that although there was a delay in publication and initial hearing dates, the governmental representation, through the Solicitor General's office, was appropriately notified, which mitigated the need for additional republication.
Propriety of Change of Name
The Court emphasized that a change of name is a privilege contingent on demonstrating justifiable reasons for such change, balanced against the interests of the state. Established grounds include avoiding confusion due to inconsistency between one’s recorded name and commonly used name, as well as avoiding embarrassment associated with one's current name. The court recognized the significance of safeguarding against possible fraudulent use while allowing legitimate adjustments to one’s identity.
Affirmation of the Lower Court’s Decision
The Court concluded that the trial court exercised its discretion correctly, affirming that the evidence provided by the respondent, despite being primarily testimonial, sufficed to establish the le
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Background of the Case
- The case under review arises from a petition for change of name filed by the respondent, Roselie Eloisa Bringas Bolante, also known as Maria Eloisa Bringas Bolante.
- The petition was initiated before the Regional Trial Court (RTC) of Bangued, Abra, and was later affirmed by the Court of Appeals (CA).
- The respondent claimed to be a Filipino citizen of legal age and married, born to Floriano B. Bolante and Paula B. Bringas, and a lifelong resident of Bangued, Abra.
- The respondent's registered name was noted as Roselie Eloisa Bringas Bolante, which she claimed not to have used, opting instead to use Maria Eloisa Bringas Bolante in all her public and private records.
Procedural History
- The RTC found the petition sufficient in form and substance and ordered compliance with jurisdictional requirements, including notice and publication, setting the hearing for February 20, 2001.
- The initial hearing was rescheduled multiple times, and the actual hearing took place on September 25, 2001, where various documents were submitted without objection from the Republic represented by the Office of the Solicitor General (OSG).
- Respondent presented evidence including school records, professional licenses, and her marriage license to support her claim for the name change.
Trial Court's Decision
- On January 23, 2002, the RTC granted the petition, allowing the change of name from Roselie Eloisa Bringas Bolante to Maria Eloisa Bringas Bolante, citing the merit of the petition and the need to avoid confusion.
Appeal to the Court of Appeals
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