GR L 70513; (October, 1986) (Digest)
G.R. No. L-70513 October 13, 1986
Republic of the Philippines, petitioner, vs. The Honorable Intermediate Appellate Court and Kenneth Wong Man Leung alias Kiana So, also known as Kenneth Wong Man Leung, etc., respondents.
FACTS
Private respondent Kenneth Wong Man Leung, a British subject born in Hong Kong, arrived in the Philippines in 1969. He was naturalized as a Filipino citizen in 1976 under Presidential Decree No. 836. His official name in his Certificate of Naturalization and with the Local Civil Registrar was “Kenneth Wong Man Leung alias Kiana So.” However, he used various permutations of this name across different documents, such as his Alien Certificate of Registration, baptismal and marriage certificates, income tax returns, and his child’s birth certificate, leading to confusion.
Kenneth filed a petition under Rule 103 to change his name to simply “Kenneth Kiana So.” He sought to adopt a shorter, more identifiable Filipino name to avoid the confusion caused by the frequent inadvertent rearrangements of the parts of his long official name, to erase signs of his former nationality which he felt hampered his social and business life, and to align himself more closely with his adopted countrymen. The Juvenile and Domestic Relations Court of Iloilo City granted the petition, a decision affirmed by the Intermediate Appellate Court.
ISSUE
Whether the Intermediate Appellate Court erred in affirming the grant of the petition for change of name.
RULING
The Supreme Court affirmed the decision, rejecting the Solicitor General’s arguments. First, the Court held the jurisdictional requirement was met. The petition stated Kenneth’s real or official name as recorded in the Local Civil Registrar—”Kenneth Wong Man Leung alias Kiana So”—the name under which he was naturalized. It also alleged his former name as a British subject. This complied with the rule requiring a statement of the petitioner’s real name.
Second, the Court found proper and reasonable cause for the change. The Intermediate Appellate Court’s factual finding of sufficient justification—including the sincere desire to adopt a Filipino name, to avoid the confusion and inconvenience stemming from multiple aliases and name permutations, and to facilitate social and business integration—was deemed conclusive. The Supreme Court emphasized it does not review factual findings supported by evidence. The change would discourage the use of aliases and provide convenience in dealing with him, which are valid grounds under jurisprudence. Therefore, no error was committed in approving the petition.