Republic v. Intermediate Appellate Court
REITERATIONFacts
The Antecedents: Private respondent, Kenneth Wong Man Leung alias Kiana So, born in Hongkong, came to the Philippines as a British subject in 1969. His initial name as per his Alien Certificate of Registration and SSS Personal Data Record was Wong Man Leung. He was baptized with the Christian name Kenneth, and his baptismal certificate listed his full name as Kenneth Wong Man Leung. He later married Maylinda Yap under the name Kenneth Wong Man Leung alias Kiana So. He was naturalized as a Filipino citizen on February 10, 1976, with his name recorded as Kenneth Wong Man Leung alias Kiana So in his Certificate of Naturalization and by the Local Civil Registrar of Iloilo City. Various other documents, including his son's birth certificate, SSS records, income tax returns, and clearances from various authorities, listed his name with different variations and aliases, such as Kiana Chuen Co, Wong Man Leung Kenneth (Kiana So), Leung Kenneth Wong Man, and Leung Kenneth. Procedural History: The Juvenile and Domestic Relations Court of Iloilo City granted the petition for change of name. The Intermediate Appellate Court affirmed this decision. The Petition: Private respondent sought to change his name from the lengthy and varied Kenneth Wong Man Leung alias Kiana So to simply Kenneth Kiana So. The grounds for the petition were the desire to have a shorter, more easily identifiable name, to adopt a Filipino name for closer association with his adopted countrymen, and because he had become publicly known as Kenneth Kiana So. He also wished to avoid confusion arising from the frequent rearrangements of the parts of his name.
Issue(s)
Whether the petition for change of name sufficiently stated the petitioner's real or official name and alleged his former name as a British subject. Whether the evidence presented established proper and reasonable cause for the change of name.
Ruling
The Court affirmed the decision of the Intermediate Appellate Court, upholding the change of name granted to the private respondent.
Ratio Decidendi
On the sufficiency of the petition and allegation of former name: The Court held that the petition fulfilled the jurisdictional requirement because, at the time of filing, the Local Civil Registrar officially showed the private respondent's name as Kenneth Wong Man Leung alias Kiana So, which was the name under which he was granted Filipino citizenship. Furthermore, the petition also alleged his former name as a British subject, "Wong Man Leung," as it appeared in his alien certificate of registration. This satisfied the requirement of stating his real or official name and his former name. On the existence of proper and reasonable cause for change of name: The Court found that the Intermediate Appellate Court's conclusion that sufficient justification existed for the change of name was a finding of fact that the Supreme Court would not review. The evidence established a sincere desire on the part of Kenneth to adopt a Filipino name to erase signs of his former nationality that could unduly hamper his social and business life. The change of name would also do away with aliases, which should be discouraged, and would avoid confusion, thereby being "for the convenience of the world at large in addressing him, or in speaking of or dealing with him." This demonstrated proper and reasonable cause for the requested change.
Main Doctrine
The Court affirmed the Intermediate Appellate Court's decision granting a petition for change of name, holding that the petition sufficiently stated the petitioner's real or official name as recorded in the Local Civil Registrar and that sufficient justification, including the desire for a shorter, more identifiable, and Filipino name to facilitate social and business interactions and avoid confusion, was established.