G.R. No. L-22607 July 30, 1969
Republic of the Philippines, petitioner, vs. Lee Wai Lam, respondent.

FACTS

On October 6, 1954, respondent Lee Wai Lam filed a petition in the Court of First Instance of Manila to change his name to “William Lee Wong.” He alleged he was a Chinese national, a resident of Manila since 1935, and that his usual name before entering the Philippines was “William Lee,” but it was mispronounced and misspelled as “Lee Wai Lam” on his Landing Certificate of Residence. He claimed “Lee” was his grandfather’s adopted family name, “Wai Lam” should have been “William,” and his ancestral family name was “Wong.” He further stated he had been known as “William Lee Wong” in his school records at Philippine Sun Yat Sen, Far Eastern University, and Mapua Institute of Technology. The Republic of the Philippines, through the Solicitor General, opposed the petition on grounds that the necessity for the change was not established and that his use of “William Lee Wong” without judicial authority violated Commonwealth Act No. 142 (the Anti-Alias Law). The lower court granted the petition, and the Court of Appeals affirmed the decision. The Republic appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the grant of the petition for change of name, specifically regarding: (1) the sufficiency of the petition’s form and the respondent’s capacity to verify it; (2) the sufficiency of evidence to prove the allegations; (3) whether the grounds for opposition were obstacles to the grant; and (4) whether there was a proper and reasonable cause to justify the change of name.

RULING

The Supreme Court REVERSED the decision of the Court of Appeals and DENIED the petition for change of name.
1. On the first assigned error, the Court found no merit. Citing Tse vs. Republic and Oshita vs. Republic, it held that a minor’s verification of a petition is not a jurisdictional defect but a formal requisite, and the court’s jurisdiction depends on the nature of the proceeding, not the capacity of the parties.
2. On the core issue of whether a “proper and reasonable cause” existed, the Court ruled it did not. The standards from Yu Chi Han vs. Republic were applied: a change of name is a privilege, not a right, and requires a proper or reasonable cause such as: (1) the name being ridiculous, dishonorable, or extremely difficult to write/pronounce; (2) a change due to a change in status (e.g., legitimation); or (3) a need to avoid confusion. Respondent’s reasons—to correct an alleged error in his landing certificate, adopt his ancestral name “Wong,” reconcile his school records (where he was known as “William Lee Wong”) with his immigration papers, and harmonize his various names—were deemed insufficient. The Court cited precedents (*Yap Ek Siu vs. Republic, Jesus Ng Yao Siong vs. Republic, Grant vs. Republic, Chiu Hap Chiu vs. Republic*) where similar reasons like filial attachment, use of a different name, confusion in records, or desire to harmonize documents were not considered proper and compelling justifications.
3. Furthermore, the Court identified a fatal defect in the publication of the petition. Citing Jesus Ng Yao Siong vs. Republic, the Court held that for a publication to be valid, the title must include the petitioner’s real name and all his aliases. The record showed respondent used six names: Lee Wai Lam, William Lee Wong, William Wong, William L. Wong, William Lee, and William W. Lee. The petition and the order for publication only mentioned “Lee Wai Lam” and the desired name “William Lee Wong,” omitting the other aliases. This omission rendered the publication invalid and warranted the petition’s dismissal.