FACTS:

The case involves a petition for adoption and change of name filed by private respondents. Petitioner argues that a petition for adoption and a petition for change of name are two separate proceedings governed by different sets of laws and rules. The trial court adopted a liberal stance and granted the change of name, considering that the child is an infant and no rights have been prejudiced. The petitioner insists on strict adherence to the rule regarding change of name to maintain the system of identification, while private respondents invoke the welfare and interest of the adoptee. The law allows the adoptee to bear the surname of the adopter, but the first or Christian name of the adoptee must remain as it was originally registered in the civil register.

The pertinent facts of this case are as follows: The petitioner filed a petition for adoption, seeking to adopt the minor child. The petition also included a request to change the adoptee's name. The court held that a change of name is a substantive and procedural matter that should be done through a separate petition for change of name and not as an incidental matter in an adoption proceeding. The court also clarified the requirements and conditions for joinder of causes of action, stating that the joinder of causes of action is permissive and not mandatory, and should only be allowed if it does not violate the rules on jurisdiction, venue, and joinder of parties, and if the causes of action arise out of the same contract, transaction, or relation between the parties, or are for demands for money or are of the same nature and character.

In this case, the petitioner filed a petition for adoption and a petition for change of name in the Regional Trial Court (RTC). The RTC dismissed the petitions, stating that the two petitions could not be joined since they were not related and did not present any common question of fact or law. The Court of Appeals (CA) affirmed the RTC's decision.

ISSUES:

1. Whether or not the court a quo erred in granting the prayer for the change of the registered proper or given name of the minor adoptee embodied in the petition for adoption.

2. Whether or not there was a lawful ground for the change of name.

RULING:

The Supreme Court found that the change of the adoptee's surname as a result of the adoption to follow that of the adopter does not extend to or include the proper or given name. It held that changing the given or proper name of the adoptee must be effected through a separate and distinct proceeding from that of the adoption. Accordingly, while the grant of adoption was affirmed, the Court ruled that the modification to change the minor's first name within the same adoption proceeding was improperly granted without adequate legal basis and in disregard of procedural requirements.

The Court emphasized that a change of name is not a mere procedural technicality but a matter of public interest and order, involving the significant alteration of one's official or legal name as recorded in the civil register. Thus, any change must comply strictly with the substantive and procedural requirements laid out in Rule 103 of the Rules of Court.

Therefore, the assailed order of the lower court granting the change of the adoptee's first name in the same proceeding as the adoption was modified. The child's name was ordered to remain as Kevin Earl Munson y Andrade unless legally changed through a properly filed petition for change of name in accordance with relevant laws and procedures.

PRINCIPLES:

1. A change of name is a matter of public interest, not merely a private concern.

2. The given or proper name and the surname of a person have distinct legal treatments; the former remains unchanged by the adoption and can only be changed through a judicial order following a separate proceeding.

3. Rules of court are to be adhered to strictly to prevent abuse and ensure orderly proceedings; procedural rules are as significant as substantive rights.

4. An adoptive relationship does not confer upon the adopter the right to change the adoptee’s registered first or given name as part of the adoption decree.

5. Adoption and change of name are separate proceedings, each governed by specific statutes and rules, and they do not satisfy the criteria for permissive joinder of causes of action under the Rules of Court.

6. Liberal construction of procedural rules is allowed only to the extent that such construction avoids injustice or clarifies procedural ambiguity, and does not excuse total disregard of the rules.

7. Technical compliance with requirements for a petition for change of name under Rule 103 is indispensable for the proper adjudication of the petition.