G.R. No. 250520 , May 05, 2021
FRANCIS LUIGI G. SANTOS, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, THE OFFICE OF THE LOCAL CIVIL REGISTRAR OF QUEZON CITY, THE CIVIL REGISTRAR GENERAL, AND ALL INTERESTED PERSONS, RESPONDENTS.

FACTS

Petitioner Francis Luigi G. Santos filed a petition under Rule 103 of the Rules of Court to change his surname from “Santos” to “Revilla” in his Certificate of Live Birth. He was born on January 9, 1992, to Lovely Maria T. Guzman and Ramon “Bong” Revilla, Jr., who was married to another woman at the time. His birth certificate initially bore the surname “Guzman” with his father marked as unknown. On April 24, 1996, Bong Revilla executed an Affidavit of Acknowledgment recognizing petitioner as his son. In 1999, Lovely Guzman married Patrick Joseph P. Santos, who legally adopted the petitioner, changing his name to “Francis Luigi G. Santos.” Petitioner claimed he grew up close to Bong Revilla’s family, was treated as a legitimate son, and used the name “Luigi Revilla” in show business. He filed the petition to avoid confusion, associate himself with the Revilla family, and ensure his records reflect his true identity as Bong Revilla’s son. The Republic, through the OSG, opposed the petition. The Regional Trial Court (RTC) denied the petition, ruling no compelling reason existed and that the change would create confusion given his legal adoption. The Court of Appeals (CA) affirmed the RTC, adding that the proper remedy was a Rule 108 proceeding for correction of entries, not Rule 103, and that the proceedings were void for failure to implead indispensable parties (his biological and adoptive fathers).

ISSUE

1. Whether the CA erred in holding that Rule 108, rather than Rule 103, applies to the petition.
2. Whether the CA erred in denying the petition to change petitioner’s surname from “Santos” to “Revilla.”

RULING

1. The CA erred in holding that Rule 108 applies. The Supreme Court ruled that petitioner correctly availed of a Rule 103 petition for change of name. Rule 103 is the proper special proceeding for changing one’s name, as it involves a change of the official name recorded in the civil register. The corrections sought did not involve mere clerical errors but a change of surname, which is within the scope of Rule 103. The Court clarified that the proceedings were not void for failure to implead indispensable parties under Rule 108, as Rule 103 has its own procedural requirements, which were complied with, including publication and notice to the OSG.
2. The CA did not err in denying the petition. The Supreme Court affirmed the denial, holding that petitioner failed to prove a compelling reason for the change of name. A change of name is a privilege, not a right, and requires proper and reasonable cause. Petitioner’s adoption by Patrick Santos legally severed his tie to his biological father and obligated him to use the surname “Santos” under the Family Code and Republic Act No. 8552 (Domestic Adoption Act of 1998). Allowing the change would create confusion regarding his legal status as an adopted child. His use of “Revilla” in show business was a screen name, not a legal name, and did not justify the change. The Court found no weighty reason to grant the petition, as it would undermine the legal effects of adoption and potentially prejudice public interest.