Santos v. Republic

Summary

Francis Luigi G. Santos sought to change his surname from 'Santos' to 'Revilla' to associate himself with his biological father Bong Revilla Jr., despite being legally adopted by Patrick Santos. The Supreme Court clarified that Rule 103 (change of name) was the proper remedy, not Rule 108 (correction of entries), but denied the petition for lack of compelling reasons. The Court emphasized that change of name is a privilege requiring proper cause, and mere desire to associate with one's biological family after legal adoption is insufficient. The decision reinforced that adopted children must use their adopter's surname unless exceptional circumstances warrant change, and that convenience or personal preference alone cannot justify name changes. The case establishes important jurisprudential guidance on the distinction between Rule 103 and Rule 108 proceedings and the stringent requirements for name change petitions in the Philippines.