Names are labels for one’s identity. They facilitate social interaction, including the allocation of rights and determination of liabilities. It is for this reason that the State has an interest in one’s name.
The name through which one is known is generally, however, not chosen by the individual who bears it. Rather, it is chosen by one’s parents. In this sense, the choice of one’s name is not a product of the exercise of autonomy of the individual to whom it refers.
In view of the State’s interest in names as markers of one’s identity, the law requires that these labels be registered. Understandably, in some cases, the names so registered or other aspects of one’s identity that pertain to one’s name are not reflected with accuracy in the Certificate of Live Birth filed with the civil registrar.
Changes to one’s name, therefore, can be the result of either one of two (2) motives. The first, as an exercise of one’s autonomy, is to change the appellation that one was given for various reasons. The other is not an exercise to change the label that was given to a person; it is simply to correct the data as it was recorded in the Civil Registry.
Republic of the Philippines vs. Michelle Soriano Gallo; GR No. 207074, January 17, 2018
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