G.R. No. 189476 ; February 2, 2011
Republic of the Philippines, Petitioner, vs. Julian Edward Emerson Coseteng-Magpayo (a.k.a. Julian Edward Emerson Marquez-Lim Coseteng), Respondent.

FACTS

Julian Edward Emerson Coseteng-Magpayo (respondent) was born on September 9, 1972, as shown by his certificate of live birth, which indicated his parents, Fulvio M. Magpayo Jr. and Anna Dominique Marquez-Lim Coseteng, were married on March 26, 1972. Claiming his parents were never legally married, respondent filed a Petition for Change of Name at the Regional Trial Court (RTC) of Quezon City to change his name to Julian Edward Emerson Marquez-Lim Coseteng. He submitted a National Statistics Office certification stating his mother did not appear in the national marriage indices, along with academic records and his child’s birth certificate showing his use of the surname “Coseteng,” and evidence he was elected as a Quezon City Councilor using the name “JULIAN M.L. COSETENG.” After compliance with publication and notice requirements, and with no opposition filed, the RTC granted the petition. The court’s decision not only ordered the change of name but also directed the Civil Registrar of Makati City to delete the entry of his parents’ marriage date, correct his last name to “COSETENG,” delete “COSETENG” from his middle name, and delete his father’s name from the birth certificate. The Republic of the Philippines, through the Office of the Solicitor General, filed a motion for reconsideration, which was denied, prompting this petition for review.

ISSUE

1. Whether the petition for change of name, which involves changing the respondent’s civil status from legitimate to illegitimate, should be made through appropriate adversarial proceedings under Rule 108 of the Rules of Court, rather than Rule 103.
2. Whether the trial court exceeded its jurisdiction by ordering the deletion of the respondent’s father’s name and the marriage entry from the birth certificate, which went beyond the relief prayed for in the petition.

RULING

The Supreme Court GRANTED the petition and NULLIFIED the RTC decision.
1. On the Proper Remedy: The Court held that the change sought by the respondent was not merely a change of name under Rule 103, but a substantial alteration of his civil status from legitimate to illegitimate. Citing Labayo-Rowe v. Republic, the Court ruled that such changes affecting civil status require appropriate adversary proceedings under Rule 108 (Cancellation or Correction of Entries in the Civil Registry). Rule 108 mandates that the petition be filed in the civil registry where the entry is sought to be corrected (Makati City, not Quezon City) and that all interested parties, including the civil registrar and the affected parents, be made parties to the proceeding. The respondent’s petition failed to comply with these requirements. The Court distinguished this case from Alfon v. Republic, where a change of name to avoid confusion was allowed without denying legitimacy, whereas here, the respondent explicitly denied his legitimacy.
2. On Jurisdiction and Relief Granted: The Court found that the trial court exceeded its jurisdiction by ordering the deletion of the father’s name and the marriage entry. The respondent’s petition prayed only for a change of name and for records to reflect that change. The additional corrections ordered by the RTC were not prayed for and constituted a substantial alteration beyond the scope of a Rule 103 proceeding. The Court emphasized that Rules 103 and 108 are separate and distinct and cannot be substituted for expediency, as held in Republic v. Belmonte.
Therefore, the RTC decision was nullified for having been rendered without proper adversarial proceedings and for granting relief beyond the petition’s scope.