November 20, 2017
Ponente: Velasco, Jr., J.
FACTS
In 2013, Eric Chua filed a petition for the change of his surname from "Kiat" to "Chua." In his petition, he alleged that his Chinese father Cheong Kiat was able to secure a judgment allowing him to change his surname from Kiat to Chua. As such, Eric has been using Eric Chua in all his IDs and credentials all his life.
Because Eric was unable to obtain a copy of said judgment, the only evidence he was able to present were his birth certificate with the last name Kiat. All his other documents, including his Certificate of Baptism, Voter Certification, Police Clearance, High School Diploma, and COLBs of his children, were all under Eric Chua.
RTC La Union granted Eric's petition.
The Republic, represented by the Office of the Solicitor General (OSG), interposed an appeal before the CA.
The CA overturned the RTC ruling. CA held that Eric failed to present proof to establish that his father, Cheong Kiat, was indeed able to secure a court judgment allowing him to officially change his surname from "Kiat" to "Chua."
Hence, the instant petition.
RULING
The Supreme Court overturned the CA's ruling and upheld RTC La Union's ruling in favor of Eric.
In Republic v. Coseteng-Magpayo, the Court enumerated several recognized grounds that can be invoked by a person desirous of changing their name, one of which is when the change of name will avoid confusion.
The SC held that in the prior case of Alfon v. Republic, the Court granted the petition for change of name of Maria Estrella Veronica Primitiva Duterte to Estrella S. Alfon on the ground that petitioner has been using the name Estrella S. Alfron all her life. Even though her birth records indicate that her name is Maria Estrella Veronica Duterte, all her documents were under Estrella S. Alfon, and all the people around her knew her by that name.
The above cited case applied in the case of Eric. The SC noted that Eric has established that he is known in his community as "Eric Chua," rather than "Eric Kiat." Additionally, all his documents, with the exception of his birth certificate, all indicate Eric Chua.
Finally, the Court held that denying Eric's petition to change his name from Kiat to Chua would have ramifications not only to Eric's identity in his community, but also to that of his children.