FACTS:

Petitioner Julian Lin Carulasan Wang, a minor represented by his mother Anna Lisa Wang, filed a petition for change of name and/or correction/cancellation of entry in the Civil Registry. He sought to drop his middle name and have his registered name changed from Julian Lin Carulasan Wang to Julian Lin Wang. The Regional Trial Court (RTC) established that Julian was born to Anna Lisa Wang and Sing-Foe Wang, who were not yet married at the time. After their marriage, a deed of legitimation was executed, changing Julian's name from Julian Lin Carulasan to Julian Lin Carulasan Wang. The parents planned to move to Singapore with their children, and they believed that Julian's current registered name would cause discrimination in Singapore since middle names are not carried there. The trial court, however, denied the petition, stating that the reason given did not fall within the grounds recognized by law and that the change sought was merely for the convenience of the child. Petitioner filed a motion for reconsideration, which was subsequently denied. Hence, the petitioner filed a Petition for Review on Certiorari with the Supreme Court, arguing that dropping the middle name of a minor child is not contrary to Article 174 of the Family Code.

ISSUES:

1. Whether or not the dropping of the middle name "Carulasan" from the child's registered name is contrary to Article 174 of the Family Code.

2. Whether or not convenience for easier integration into another country's society constitutes a proper and reasonable cause for the change of name.

RULING:

1. Dropping the Middle Name

   • The Supreme Court held that the law does not allow an individual to drop the middle name from his registered name. Article 174 of the Family Code gives legitimate children the right to bear the surnames of both the father and the mother. Dropping the middle name "Carulasan" would effectively remove the legal recognition of this maternal lineage, which is not permissible under law.

2. Proper and Reasonable Cause for Change of Name

   • The Court ruled that convenience for easier integration into Singaporean society does not constitute proper or reasonable cause for the change of name. Petitioner's reason for change – to avoid potential embarrassment and difficulty in writing or pronouncing the middle name "Carulasan" in Singapore – was determined to be insufficient and merely a matter of convenience. The State has an interest in maintaining the integrity of an individual's name as recognized under Philippine law, which outweighs the petitioner's grounds for change.

PRINCIPLES:

• State Interest in Names The State has an interest in the names borne by individuals for purposes of identification. Changes to a name are a privilege, not a right, and thus require a compelling reason.

• Proper and Reasonable Cause To justify a change of name, there must be a proper, reasonable, or compelling cause. Convenience or potential ease of integration into another society does not suffice.

• Legal Significance of Middle Names Middle names serve to identify the maternal lineage or filiation of a person and help further distinguish an individual. Dropping a middle name affects the legal recognition of maternal lineage.

• Article 174 of the Family Code Legitimate children have the right to bear the surnames of both their father and mother.

• Matters of Minor's Name Changes to a minor’s name should consider future autonomy. Decisions of this nature are best left until the individual reaches the age of majority.