Case Summary (G.R. No. 250520)
Petitioner
Francis Luigi G. Santos, legally adopted by Patrick Santos in 1999, currently bearing the surname “Santos,” petitions under Rule 103 for judicial change of name to “Francis Luigi G. Revilla.”
Respondent
Republic of the Philippines (Office of the Solicitor General), Office of the Local Civil Registrar of Quezon City, Civil Registrar General, and all interested persons.
Key Dates
- January 9, 1992: Petitioner’s birth.
- April 24, 1996: Biological father’s Acknowledgment of Paternity.
- 1999: Adoption by Patrick Santos.
- April 30, 2018 & July 20, 2018: RTC Decision and Order denying name-change petition.
- August 28, 2019 & November 20, 2019: CA Decision and Resolution affirming RTC.
- May 5, 2021: Supreme Court Decision.
Applicable Law
- 1987 Philippine Constitution
- Civil Code Articles 376 (name change) and 408–412 (civil registry)
- Rules of Court, Rule 103 (change of name) and Rule 108 (correction/cancellation of entries)
- R.A. 8552 (Domestic Adoption Act of 1998)
- R.A. 9048 and R.A. 10172 (administrative clerical corrections)
Background Facts
Petitioner was born out of wedlock; his birth certificate bore no father. Bong Revilla acknowledged paternity in 1996. Lovely Guzman married Patrick Santos in 1999, who adopted petitioner, changing his surname to “Santos.” Petitioner grew up in both families, used “Luigi Revilla” in show business, and now seeks to align his legal surname with his biological lineage.
Procedural History – RTC
RTC Branch 225 found petitioner’s Rule 103 petition sufficient but, upon hearing, denied it. The court held that adoption severs legal ties to biological parents, obligating the adoptee to bear the adopter’s surname. No compelling reason justified changing “Santos” to “Revilla,” as petitioner never legally used “Revilla” outside his stage name.
Procedural History – Court of Appeals
CA First Division affirmed the RTC. It ruled that petitioner should have used Rule 108 adversarial proceedings for substantial registry changes rather than Rule 103 and that failure to implead both biological and adoptive fathers rendered the proceedings void. It emphasized that an adopted child must bear the adopter’s surname under the Family Code and R.A. 8552.
Issues
- Whether Rule 108 instead of Rule 103 applies to petitioner’s name-change request.
- Whether petitioner established compelling reasons for changing his surname from “Santos” to “Revilla.”
Ruling – Rule 103 Applicability
The Supreme Court held that Rule 103 governs change-of-name petitions where no registry error or status correction is sought. Rule 108 applies only to cancellation or correction of registry entries. Petitioner sought to replace his surname without alleging any registry error or status change, making Rule 103 the correct remedy.
Ruling – Compelling Reason Standard
A name change is a privilege requiring proof of proper and compelling causes and prejudice from use of the of
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Facts and Antecedent Proceedings
- Petitioner Francis Luigi G. Santos filed a petition under Rule 103 of the Rules of Court to change his surname from “Santos” to “Revilla” in his Certificate of Live Birth.
- He was born “Francis Luigi Guzman” on January 9, 1992 in Quezon City to Lovely Maria T. Guzman and Jose Marie Bautista, Jr. (Ramon Bong Revilla, Jr.).
- His parents never married; his father was already married to Lani Mercado. Petitioner’s birth certificate bore his father as “unknown.”
- On April 24, 1996, Bong Revilla executed an Affidavit of Acknowledgment recognizing the petitioner as his son.
- In 1999, Lovely Guzman married Patrick Joseph P. Santos, who legally adopted the petitioner in 2001, changing his name to “Francis Luigi G. Santos.”
- Petitioner was raised by his adoptive father but maintained close ties with Bong Revilla’s family and used the screen name “Luigi Revilla” in show business.
- He sought the surname “Revilla” to avoid confusion, to publicly associate with the Revilla family, and to reflect his true paternity.
- On June 19, 2017, the RTC ordered publication and notice of the petition; the Office of the Solicitor General filed an opposition claiming no compelling reason justified the change.
Ruling of the Regional Trial Court
- In its April 30, 2018 Decision, the RTC denied the petition, holding that a change of name is a privilege, not a right, and requires compelling grounds.
- The court found petitioner failed to justify the requested change and that adopting “Revilla” would create confusion given his lawful adoption by the Santos family.
- It noted adoption severs legal ties with biological parents and obligates the adoptee to use the adopter’s surname under R.A. 8552.
- The petitioner had never legally used “Revilla” except as a screen name; all official documents since adoption bore “Santos.”
Ruling of the Court of Appeals
- The CA, in its August 28, 2019 Decision and November 20, 2019 Resolution, affirmed the RTC.
- It held that a change of surname would conflict with the Family Code and R.A. 8552,