G.R. No. 160597 July 20, 2006
Republic of the Philippines, petitioner, vs. Roselie Eloisa Bringas Bolante a.k.a. Maria Eloisa Bringas Bolante, respondent.

FACTS

Respondent Roselie Eloisa Bringas Bolante filed a petition for change of name before the Regional Trial Court (RTC) of Bangued, Abra. She alleged that while her registered name in her birth certificate is “Roselie Eloisa Bringas Bolante,” she has never used it. Instead, she has consistently used the name “Maria Eloisa Bringas Bolante” in all her school, public, and private records, including her professional license and marriage certificate. Her purpose was to align her registered name with the name she has always carried to prevent confusion, particularly for securing a passport and avoiding complications upon retirement.
The RTC granted the petition after finding jurisdictional requirements of notice and publication were satisfied and that respondent testified she had not been accused of any crime under either name. The Republic, through the Office of the Solicitor General, appealed, arguing the trial court lacked jurisdiction due to non-compliance with procedural rules and that respondent failed to prove the petition was not for an illegal purpose, as she did not present NBI or police clearances. The Court of Appeals affirmed the RTC decision, prompting the Republic to elevate the case to the Supreme Court via a petition for review.

ISSUE

The core issues are: (1) whether respondent’s compliance with jurisdictional requirements under Rule 103 of the Rules of Court was sufficient to vest the trial court with jurisdiction; and (2) whether her testimony alone, without supporting clearances, was adequate to prove the change of name was not for an illegal purpose.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. On jurisdiction, the Court held that respondent substantially complied with Sections 2 and 3 of Rule 103. She presented evidence, including a certificate of posting and an affidavit of publication, demonstrating that the notice of hearing was published in a newspaper of general circulation. This compliance was sufficient to confer jurisdiction upon the RTC, as strict, not perfect, compliance is required for change of name proceedings.
Regarding the purpose of the petition, the Court ruled that respondent’s testimony in open court, affirming the change was to avoid confusion and not for fraud, was sufficient. The Rules of Court do not mandate the submission of NBI or police clearances as proof of lawful intent. The absence of any opposition to the petition further supported its legitimacy. The Court emphasized that change of name is a privilege within judicial discretion, granted when justified to prevent confusion, as in this case where respondent’s lifelong use of a name different from her registered one created practical difficulties. The trial court exercised its discretion judiciously, and no reversible error was committed.