G.R. No. L-32054 May 15, 1974
TERESITA LLANETA (known also as TERESITA LLANETA FERRER and TERESITA FERRER), petitioner, vs. The Honorable CORAZON JULIANO AGRAVA, as Presiding Judge of the Juvenile and Domestic Relations Court of Manila, respondent.

FACTS

Petitioner Teresita Llaneta was born out of wedlock to Atanacia Llaneta after the death of Atanacia’s lawful husband, Serafin Ferrer. Raised in the Ferrer household by her grandmother-in-law, Victoria vda. de Ferrer, Teresita used the surname “Ferrer” throughout her life, in all her school records and social dealings. It was only when she was about twenty years old and applied for a copy of her birth certificate for a scholarship that she discovered her registered surname was “Llaneta,” reflecting her illegitimate status as the child of Atanacia and an unknown father.
To avoid the confusion and difficulties that would arise from suddenly using her legal surname “Llaneta” after a lifetime of being known as “Ferrer,” Teresita filed a petition with the Juvenile and Domestic Relations Court to change her name to “Teresita Llaneta Ferrer.” The respondent judge denied her petition, prompting this appeal by certiorari. The denial was based on the doctrine that a change of name should not be permitted if it would create a false impression of family relationship.

ISSUE

Whether the petitioner should be allowed to change her name from Teresita Llaneta to Teresita Llaneta Ferrer.

RULING

The Supreme Court reversed the lower court’s decision and granted the petition. The Court clarified that the doctrine prohibiting a name change that suggests a non-existent family relationship remains valid, but only to the extent that such a change would likely cause prejudice or future mischief to the family whose surname is involved or to the community. In this case, no such prejudice or mischief was present.
The legal logic centered on a balance of interests. The petitioner established that a forced reversion to “Llaneta” would cause significant confusion in her personal, academic, and official life, requiring endless explanations and affidavits. Crucially, the living members of the Ferrer family—Serafin’s mother and brothers—actively supported her petition and took pride in sharing their surname with her. There was no opposition from any relative or from the State, which has an interest in the clear identification of its citizens. The Court emphasized that the law should allow her to continue in society without her illegitimate status being unnecessarily highlighted at every turn, as her use of “Ferrer” was a long-standing fact tolerated by the only persons with a direct interest in the name. Therefore, the change was justified to prevent confusion and reflect the reality of her lifelong identity, with no evidence of fraudulent intent or harm to the Ferrer family.