The Supreme Court has ruled that a minor child cannot drop their middle name merely for convenience, especially when the reasons provided are not compelling and the child’s best interests are not clearly demonstrated. This decision underscores the legal significance of a person’s name, including the middle name, and emphasizes that changes to one’s name are a privilege, not a right, requiring substantial justification.

The Case of Julian Lin Wang: Can a Middle Name Be Dropped for Convenience?

The case revolves around Julian Lin Carulasan Wang, a minor represented by his mother, who sought to drop his middle name, Carulasan, to avoid potential discrimination while studying in Singapore, where middle names are not commonly used. The Regional Trial Court (RTC) denied the petition, citing that the reasons provided did not fall within legally recognized grounds for a change of name. The RTC emphasized that legitimate children have a right to bear both their father’s and mother’s surnames, as enshrined in Article 174 of the Family Code.

The Supreme Court affirmed the trial court’s decision, emphasizing that a change of name requires “proper and reasonable cause.” The Court reiterated that the State has a vested interest in the names individuals bear for identification purposes. A change of name is a privilege, not a right, and requires compelling reasons to justify it. The Court has previously recognized grounds for change of name, including names that are ridiculous, dishonorable, or extremely difficult to pronounce; changes resulting from legitimation; avoidance of confusion; continuous use of a different name since childhood; a sincere desire to adopt a Filipino name; and when the surname causes embarrassment, provided the change is not for fraudulent purposes and does not prejudice public interest.

The Court addressed the legal significance of middle names, explaining that they serve to identify a person’s maternal lineage and distinguish them from others with the same given name and surname. Philippine laws dictate that legitimate and legitimated children shall use the surname of the father, and the Family Code grants them the right to bear both the surnames of the father and the mother. In contrast, illegitimate children use their mother’s surname, unless their father recognizes their filiation. This recognition can lead to the child bearing both the mother’s surname as a middle name and the father’s surname as the last name.

In this context, the court examined whether dropping the middle name is permissible under Philippine law. The petitioner argued that it would be in his best interest to drop his middle name to integrate more easily into Singaporean society. However, the Court found this reason insufficient. It distinguished this case from previous ones where changes of name were granted, noting that those cases involved petitioners who were of age and had compelling reasons, such as avoiding confusion or addressing tangible animosity towards a foreign surname. The Court distinguished this case from precedents such as Oshita v. Republic and Calderon v. Republic, emphasizing that in Calderon, the change of name was allowed for an illegitimate child to eliminate the stigma of illegitimacy.

The Supreme Court highlighted that the petitioner’s primary reason—convenience—did not meet the threshold of “proper and reasonable cause.” The Court stated that the petitioner, being a minor, might not fully understand the implications of such a change. It would be best to leave the decision to his discretion when he reaches the age of majority. Furthermore, the Court emphasized that it was not clearly established how dropping the middle name would facilitate his integration into Singaporean society, nor was it proven that continuing to use his middle name would cause significant confusion or difficulty.

Ultimately, the Supreme Court’s decision reinforces the significance of a person’s full name, including the middle name, and clarifies that a change of name is not a matter of mere convenience but requires substantial legal justification. The ruling also underscores the importance of considering the best interests of the child in such matters and highlights that a minor’s decision regarding their name should ideally be made when they reach the age of majority and can fully understand the implications of such a change.

Here is the controlling provision from the Family Code related to legitimate children’s rights:

Art. 174. Legitimate children shall have the right: (1) To bear the surnames of the father and mother, in conformity with the provisions of the Civil Code on Surnames; …

The Court also referred to previous decisions in cases involving change of name, and summarized the general view 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 right, so that before a person can be authorized to change his name given 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.

FAQs

What was the key issue in this case?	The key issue was whether a minor child could legally drop their middle name solely for convenience, particularly to avoid potential discrimination while studying abroad.
Why did the court deny the petition?	The court denied the petition because the reason provided was not a legally recognized ground for a change of name, and it was not clearly shown that the change was in the child’s best interests.
What does Philippine law say about middle names?	Philippine law recognizes the importance of middle names for identifying maternal lineage and distinguishing individuals with similar given names and surnames.
Can a legitimate child choose not to use their middle name?	While legitimate children have the right to use both their father’s and mother’s surnames, the court’s decision suggests that removing the middle name requires a compelling reason beyond mere convenience.
At what age can a person decide to change their name?	The court indicated that it is best for a person to make decisions about changing their name when they reach the age of majority and can fully understand the implications.
What are some valid grounds for changing a name in the Philippines?	Valid grounds include when the name is ridiculous, dishonorable, or difficult to pronounce; when the change results from legitimation; to avoid confusion; or when the surname causes embarrassment, without fraudulent intent.
How does this case relate to the Family Code of the Philippines?	This case interprets Article 174 of the Family Code, which grants legitimate children the right to bear the surnames of both parents. The court clarified that this right does not automatically allow for the removal of the middle name without proper justification.
Is a change of name a right or a privilege?	The Supreme Court has consistently held that a change of name is a privilege, not a right, and requires proper and reasonable cause.

This case highlights the legal and social significance of a person’s name, particularly the middle name, in the Philippines. It clarifies that changes to one’s name are not easily granted and require a compelling reason beyond mere convenience, especially when involving minors. This decision also reaffirms the State’s interest in maintaining the integrity of individuals’ identities as recorded in official documents.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: IN RE: PETITION FOR CHANGE OF NAME AND/OR CORRECTION/CANCELLATION OF ENTRY IN CIVIL REGISTRY OF JULIAN LIN CARULASAN WANG, G.R. NO. 159966, March 30, 2005