GR L 25437; (April, 1969) (Digest)
G.R. No. L-25437, April 28, 1969
IN THE MATTER OF THE CHANGE OF NAME OF YAP EK SIU, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Petitioner-appellee Yap Ek Siu, a Chinese citizen, filed a petition in the Court of First Instance of Negros Oriental to change his name to William Tanchon. He alleged that since childhood, his Filipino playmates called him “William,” and he desired to change his surname to “Tanchon” out of respect for his father, Pio Tanchon, who had been authorized by the court to use that name and was a naturalized Filipino citizen. The petitioner clarified that he remained a Chinese citizen and that his petition was not intended to evade civil obligations. The Republic of the Philippines, through the City Fiscal of Dumaguete, opposed the petition. The lower court granted the petition, finding proper and reasonable cause for the change. The Republic appealed.
ISSUE
Whether the petitioner has shown proper or reasonable cause, or any compelling reason, to justify the judicial grant of a change of name.
RULING
The Supreme Court reversed the decision of the lower court and denied the petition for change of name. The Court held 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 standard for granting a petition includes: (1) the name being ridiculous, dishonorable, or extremely difficult to write or pronounce; (2) the change being a consequence of a change in status, such as acknowledgment or legitimation; or (3) the change being necessary to avoid confusion. The petitioner failed to meet this standard. His reasons—being called “William” since childhood and a sense of filial respect for his naturalized father—did not constitute proper or reasonable cause. Furthermore, as a Chinese citizen, changing his name to a Filipino name (William Tanchon) would likely create confusion and embarrassment in his social and business dealings, as he might be mistaken for a Filipino. His real name, Yap Ek Siu, appeared on all his important documents, and he had never used “William” in business dealings. Thus, the change would be productive of confusion rather than avoid it.