G.R. No. L-22040 November 29, 1965
Yu Chi Han, petitioner-appellant, vs. Republic of the Philippines, oppositor-appellee.

FACTS

Petitioner Yu Chi Han filed a petition before the Court of First Instance of Basilan City to change his name to Alejandro Go Yu. He alleged that since his birth, he has been called Alejandro and was known as Alejandro Yu in the schools he attended. He was baptized in the Catholic faith on October 29, 1961, and was given the name Alejandro Go Yu. He sought the change to avoid confusion and to comply with the requirements of his newly acquired Catholic faith. The court denied the petition, finding no compelling reason for the change and stating it would cause more confusion as he is known in the community both as Alejandro Go Yu and by his registered name, Yu Chi Han. Petitioner appealed the denial.

ISSUE

Whether the petitioner has shown proper, reasonable, or compelling cause to justify the judicial change of his name from Yu Chi Han to Alejandro Go Yu.

RULING

The Supreme Court affirmed the denial of the petition. The Court ruled that a change of name is a privilege, not a right, and requires the petitioner to show proper or reasonable cause or a compelling reason. The Court cited established grounds for a name change, such as when the name is ridiculous, dishonorable, or extremely difficult; when it follows a change of status like legitimation; or when necessary to avoid confusion. The petitioner failed to show any such proper or compelling reason. The record indicated his true and registered name is Yu Chi Han, as evidenced by his alien certificate, school records, income tax return, and government clearances. The confusion he cited was mainly due to his own unauthorized use of a different name on various occasions. This situation could be remedied by simply having his associates use his true name, Yu Chi Han, rather than through a judicial change. His petition did not fall under any of the recognized grounds warranting a change of name. The decision appealed from was affirmed.