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Under Art. 376 of the Civil Code, no person can change his name or
surname without juridical authority. Since it involves substantial
changes, the objective is the prevention of fraud.
To establish the status of a person involving his relation with others, that
is, his legal position in, or, with regard to the rest of the community
The State has an interest in the names borne by individuals and entities
for purposes of identification. A change of name is a privilege and not a
right, so that before a person can be authorized to change his name, he
must show proper or reasonable cause, or any compelling reason which
may justify such change.
Under Art. 176 of the Civil Code, Giovanni is entitled to change his name
as he was never recognized by his father while his mother has always
recognized him as her child. A change of name will erase the impression
that he was ever recognized by his father. It is also his best interest as it
will facilitate his mothers intended petition to have him join her in the
United States. The Court will not stand in the way of the reunification of
mother and son. (Republic of the Philippines vs. Capote)
The court shall grant the petition under Rule 103 only when satisfactory
proof has been presented in open court that the order had been
published as directed, the allegations in the petition are true, and proper
and reasonable causes appear for changing the name of the petitioner.
(A.M. No. 06-7-414-RTC, October 19, 2007)