Republic v. Court of Appeals (Maximo Wong)

Summary

The Supreme Court affirmed the grant of petition to change name from Maximo Wong to Maximo Alcala Jr. The petitioner, originally named Maximo Alcala Jr., was adopted at age 2½ and took the Chinese surname Wong. At age 22, he sought to revert to his original name, claiming the Chinese surname caused embarrassment and business difficulties in his Muslim community in Cotabato City. The Court held that while Civil Code Article 365 requires adopted children to use the adopter's surname, this does not bar resort to Rule 103 for judicial change of name. The Court found proper grounds existed: genuine embarrassment affecting social and business life, with the adoptive mother's consent and no prejudice to the state. The decision establishes that adopted children may petition for name change under exceptional circumstances with proper judicial authority, balancing the mandatory surname provisions with individual welfare and legitimate grounds for change.