G.R. No. 231998, November 20, 2017
ERIC SIBAYAN CHUA, Petitioner, vs. REPUBLIC OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Eric Sibayan Chua filed a petition to change his surname from “Kiat” to “Chua” in his birth certificate. He alleged he was born to a Chinese father, Cheong Kiat, and a Filipino mother, Melania Sibayan. He claimed his father had legally changed his own surname from “Kiat” to “Chua” via a court judgment, leading petitioner to adopt “Chua” in all his personal records and community dealings. His mother testified that “Chua” was the surname his father used in the Philippines and that “Kiat” was erroneously registered due to her uncle’s mistake. Petitioner presented multiple documents—baptismal certificate, voter ID, police clearance, NBI clearance, passport, diploma, and his children’s birth certificates—all bearing the name “Eric Sibayan Chua.”
The Regional Trial Court granted the petition, viewing the change as a mere correction to align his records. The Republic appealed. The Court of Appeals reversed the RTC, dismissing the petition. The CA found petitioner failed to provide preponderant evidence of his father’s alleged legal name change. It also ruled he did not establish a compelling reason for the change or demonstrate any prejudice from using his registered name.

ISSUE

Whether the Court of Appeals erred in disallowing the petition for change of name.

RULING

The Supreme Court granted the petition, reversing the CA and reinstating the RTC decision. The legal logic centered on the recognized ground of avoiding confusion, which constitutes a valid basis for a name change under jurisprudence, such as Republic v. Coseteng-Magpayo. While petitioner’s evidence regarding his father’s name change was insufficient, his consistent use of “Chua” since childhood in all official and community interactions established a separate, compelling justification.
The Court emphasized that compelling petitioner to revert to “Kiat” would cause significant confusion, as all his credentials, identity documents, and his children’s birth records already bear “Chua.” This discrepancy between his legal birth certificate and his lifelong public identity would necessitate burdensome alterations to multiple records, affecting both his and his children’s identities. Furthermore, the State failed to show any prejudice to public interest from granting the change. Thus, the imperative to prevent confusion and maintain consistency in his official identity warranted the correction of his birth certificate to reflect the surname he has always used.