April 28, 1969
Ponente: Fernando, J.
FACTS
In 1965, Yap Ek Siu filed a petition before the CFI of Negros Oriental to change his name to William Tanchon. He did so for two reasons: (a) since his childhood days, his Filipino playmates called him William; and (b) he wanted to honor his father named Pio Tanchon, a Chinese national who became a naturalized Filipino.
In his petition, Yap Ek Siu noted that he was still a Chinese citizen, and that his intention in filing this petition for change of name was not to escape or evade his civil obligations, as in fact he had filed his income tax returns in the previous year.
Despite the opposition filed by the City Fiscal of Dumaguete, Yap Ek Siu's petition was granted by the lower court. Hence, the instant petition.
RULING
The Supreme Court overturned CFI's decision for the following reasons:
- Yap Ek Siu was a Chinese national when he filed his petition;
- Granting his petition to change his name would cause confusion, as it would make it appear that Yap Ek Siu and William Tanchon are two different persons. The SC rues that a Chinese citizen using a Filipino name will only create embarrassment and confusion in said Chinese national's social and business dealings on the ground that he might be mistaken to be a Filipino when in fact and in truth he is a Chinese; and
- Yap Ek Siu failed to prove that his name is ridiculous, or tainted with dishonor or extremely difficult to write or pronounce.
In Yu Chi Han v. Republic, Justice J.B.L. Reyes wrote that the State has an interest in the names borne by individuals and entities for purposes of identification, and that a change of name is a privilege and not a matter of right. Before a person can be authorized to change his name that was given to him either in his certificate of birth or civil registry, he must show proper or reasonable cause, or any compelling reason which may justify such change. Otherwise, the request should be denied.