In re

Summary

This case involved Honorato Catindig's petition to adopt his illegitimate child Stephanie and allow her to use her mother's surname 'Garcia' as her middle name. The trial court granted adoption but denied the use of mother's surname as middle name, ruling no law permits this. The Supreme Court reversed, holding that while no law explicitly allows it, none prohibits it either. The Court emphasized that adoption statutes should be liberally construed in favor of the child's best interest. Since adoption makes Stephanie a legitimate child entitled to all rights of legitimate children, and considering Filipino custom of using mother's surname as middle name, she should be allowed to use 'Garcia' as her middle name. This maintains her maternal lineage, eliminates stigma of illegitimacy, and preserves family relationships while ensuring her continued rights as intestate heir of her biological mother.