GR L 20018; (April, 1966) (Digest)
G.R. No. L-20018; April 30, 1966
CHIU HAP CHIU, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Chiu Hap Chiu, a 30-year-old single medical doctor and Chinese citizen residing in Davao City, filed a petition before the Court of First Instance of Davao to change his name to Lo Hap Chiu. He testified that Lo Hap Chiu was the name given to him at birth and the name he used throughout his schooling, from elementary to college. He sought the change to avoid confusion, as his current name and surname are identical (“Chiu Hap Chiu”). His alien certificate of registration, however, lists his name as Chiu Hap Chiu. The lower court granted the petition, noting his clean criminal record, tax compliance, and his desire to adopt the name used during his education. The government opposed, arguing insufficient justification for the change.
ISSUE
Whether the petitioner has shown proper or compelling reasons to warrant a change of name under Philippine law.
RULING
The Supreme Court reversed the lower court’s order and denied the petition. It held that a change of name is a privilege, not a right, and requires proper or compelling justification, such as: (1) the name being ridiculous, dishonorable, or extremely difficult to write/pronounce; (2) a change in civil status (e.g., acknowledgment of a natural child); or (3) the need to avoid confusion. The petitioner failed to prove such reasons. His claim that Lo Hap Chiu was his birth name and school name was inadequately supported—only his testimony and a University of Santo Tomas medical degree certificate showed the name “Lo Hap Chiu,” while no documentary evidence (e.g., school records) substantiated its use from grade school to college. Crucially, his official identity as an alien was consistently “Chiu Hap Chiu” in Bureau of Immigration records and clearances, and he was referred to as “Dr. Chiu Hap Chiu” in a court clearance. The State has a legitimate interest in maintaining an individual’s name for identification, especially for aliens, and no prejudice from using his official name was shown. Thus, no plausible reason existed to authorize the change.