Grounds for change of first name, nickname
While the grounds for change of name under Rule 103 are found in jurisprudence, the grounds for change of first name or nickname are expressly provided in R.A. 9048, Section 4, viz.:
In Bartolome v. Republic, petitioner sought to change his first name from "Feliciano " to "Ruben, " on the ground that he has been using the latter since childhood.[3] Contrary to petitioner's claims, the change sought is covered by R.A. 9048 and should have been filed with the local civil registry of the city or municipality where the record being sought to be corrected or changed is kept.[4]
SECTION 4. Grounds for Change of First Name or Nickname. — The petition for change of first name or nickname may be allowed in any of the following cases:In Republic v. Sali,[1] the Supreme Court held that a change of therein respondent Lorena Omapas Sali's first name from "Dorothy" to "Lorena" was primarily administrative in nature and should be filed under the procedure provided in R.A. 9048.[2]
(1) The petitioner finds the first name or nickname to be ridiculous, tainted with dishonor or extremely difficult to write or pronounce;
(2) The new first name or nickname has been habitually and continuously used by the petitioner and he has been publicly known by that first name or nickname in the community; or
(3) The change will avoid confusion.
In Bartolome v. Republic, petitioner sought to change his first name from "Feliciano " to "Ruben, " on the ground that he has been using the latter since childhood.[3] Contrary to petitioner's claims, the change sought is covered by R.A. 9048 and should have been filed with the local civil registry of the city or municipality where the record being sought to be corrected or changed is kept.[4]
[1] Republic v. Sali, 808 Phil. 343 (2017).
[2] Id. at 350.
[3] https://www.projectjurisprudence.com/2021/08/gr-no-243288-august-28-2019.html.
[4] R.A. 9048, Sec. 3.
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