### Facts:
Maximo Wong, originally named Maximo Alcala, Jr., was the legitimate son of Maximo Alcala, Sr., and Segundina Y. Alcala. At the age of two and a half, he and his sister were adopted by Hoong Wong and Concepcion Ty Wong, both naturalized Filipinos, following the couple’s decision due to their childlessness after fifteen years of marriage. Upon reaching twenty-two years of age, Maximo Wong, by then married and an engineering student, filed a petition to change his name back to Maximo Alcala, Jr., expressing discomfort and isolation due to carrying a Chinese surname in a Muslim community, affecting his social and business life negatively. The trial court agreed and granted his petition on July 2, 1986. The Republic of the Philippines, through the Solicitor General, appealed against this decision, but the Court of Appeals affirmed the trial court’s decision, prompting the filing of a petition for review on certiorari by the Republic to the Supreme Court.
### Issues:
1. Whether the reasons provided by Maximo Wong for the name change are valid, sufficient, and proper to warrant the granting of the petition.
2. Whether the desired reversion to his original surname violates Articles 341 and 365 of the Civil Code, which requires an adopted child to use the surname of the adopter.
### Court’s Decision:
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, citing that the State, or the Republic in this case, has an interest in the names borne by individuals for identification purposes. However, a change of name is not a matter of right but of judicial discretion based on proper and reasonable cause. The court acknowledged the substantial and valid reasons for Maximo Wong’s request to change his name and recognized the lack of prejudice or injury it would cause to the state or other persons. The Court emphasized that change of name is a special proceeding that involves a judicious evaluation of the justifications presented.
### Doctrine:
The case reiterated the doctrine that the State has an interest in the names of individuals for identification but recognized that the change of name is a privilege subject to judicial discretion based on proper or reasonable cause.
### Class Notes:
– **Legal Status of Name Change:** Change of name is not a right but a privilege, subject to the court’s discretion based on proper and reasonable cause.
– **Impact of Adoption on Surname:** Adoption typically requires the adopted child to use the surname of the adopter, but this requirement can be judicially adjusted for valid reasons.
– **Judicial Proceedings for Name Change:** A petition for change of name is a special proceeding that must comply with jurisdictional requirements, particularly regarding publication, to vest the court with jurisdiction.
– **Criteria for Name Change Approval:** Courts evaluate petitions for change of name based on the sufficiency of reasons provided and the potential consequences of granting the petition.
### Historical Background:
The case highlights the nuanced approach of Philippine law towards the issue of name changes, especially in the context of adoption and the interplay between cultural identities and legal principles governing surnames. It reflects the legal system’s adaptability and consideration for individual circumstances in the application of laws related to family relations and personal identity.
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