I. Introduction

In the Philippines, many married women use their husband’s surname after marriage, including on government IDs and passports. Later, some wish to return to their maiden name even though the marriage still exists and there is no annulment, declaration of nullity, legal separation, divorce recognition, or death of the spouse.

The common question is:

Can a married person revert to a maiden name on a Philippine passport without annulment?

In general, under Philippine passport practice, a married woman who has already used her husband’s surname in a Philippine passport usually cannot simply revert to her maiden surname in her passport while the marriage remains legally subsisting, unless she falls under a recognized legal ground such as annulment, declaration of nullity, recognition of foreign divorce, death of the spouse, or other legally recognized basis accepted by the Department of Foreign Affairs.

However, the answer requires careful legal discussion because Philippine law does not absolutely force a married woman to use her husband’s surname in the first place. The issue becomes more complicated once she has already elected to use the married surname in official passport records.

II. The Legal Nature of a Married Woman’s Surname in the Philippines

Under Philippine civil law, marriage does not automatically erase a woman’s maiden name. A woman’s birth name remains part of her legal identity. The law allows, but does not strictly require, a married woman to use her husband’s surname.

Under the Civil Code, a married woman may use:

Her maiden first name and surname, plus her husband’s surname;
Her maiden first name and her husband’s surname;
Her husband’s full name, with a prefix indicating that she is his wife.

In ordinary explanation, a married woman may choose to use a married name, but she is not automatically stripped of her maiden surname.

This distinction is important:

Before a married woman changes her passport to a married surname, she may generally continue using her maiden name.
After she has changed her passport to her married surname, reverting to her maiden surname is treated differently by passport authorities.

The problem is not that the maiden name no longer exists. The problem is that the passport record has already been changed to reflect the married surname, and the government generally requires a legal basis before changing it back.

III. Philippine Passport Practice: First-Time Use of Married Name Versus Reversion

A key distinction must be made between:

Keeping the maiden name after marriage, and
Reverting to the maiden name after already using the married surname in a passport.

These are not the same.

A. Married but still using maiden name

If a married woman never changed her passport to her married surname, she may generally continue using her maiden name on her Philippine passport. Marriage alone does not necessarily compel her to adopt the husband’s surname on the passport.

This means a married woman may be married in civil status but still carry a passport under her maiden surname, especially if she has consistently used her maiden name in her passport records.

B. Married and already using married surname

If a married woman previously chose to use her husband’s surname in her Philippine passport, the Department of Foreign Affairs generally treats reversion to maiden name as a substantial change in passport identity records.

In that situation, a simple personal preference, marital conflict, separation-in-fact, or desire to use the maiden name again is usually not enough. A legal basis is commonly required.

IV. Can a Married Person Revert to a Maiden Name Without Annulment?

A. General rule

A married woman who has already used her married surname in her Philippine passport generally cannot revert to her maiden surname solely by request while the marriage remains valid and subsisting.

In ordinary terms:

If the marriage still legally exists, and the passport already bears the husband’s surname, the DFA will usually not allow reversion to maiden name unless there is a recognized legal ground.

The usual recognized legal grounds include:

Death of the husband;
Annulment of marriage;
Declaration of nullity of marriage;
Judicial recognition of foreign divorce, where applicable;
Divorce decree recognized under Philippine law for a Filipino whose foreign spouse obtained divorce;
Other court-recognized change in civil status or name.

Without any of these, reversion is generally not treated as a simple renewal or correction.

B. Separation-in-fact is not enough

A married woman may be separated from her husband for years. They may no longer live together. They may no longer communicate. They may have separate partners. They may have a private agreement to separate.

Still, under Philippine law, separation-in-fact does not dissolve marriage.

Therefore, separation-in-fact generally does not provide a sufficient legal basis to revert to maiden surname in a passport once the married surname has already been adopted.

C. Legal separation is usually not the same as annulment

A decree of legal separation does not dissolve the marriage bond. It allows spouses to live separately and may affect property relations, support, and other obligations, but the parties remain married.

Because legal separation does not restore the woman to the status of being unmarried, it may not automatically have the same passport-name effect as annulment, declaration of nullity, death of spouse, or recognized divorce.

Whether a particular document will be accepted depends on DFA rules and the specific case, but as a legal concept, legal separation is not equivalent to annulment.

V. Why Annulment or Declaration of Nullity Matters

In Philippine law, annulment and declaration of nullity are court processes that affect marital status.

A. Annulment

Annulment applies to a marriage that was valid until annulled by court judgment. Once annulled, the marital bond is legally dissolved from the time of the final judgment, subject to legal effects.

B. Declaration of nullity

Declaration of nullity applies to a void marriage. A court declares that the marriage was void under law. This may involve grounds such as psychological incapacity, bigamous marriage, lack of essential or formal requisites, incestuous marriage, or other grounds recognized by law.

C. Effect on passport reversion

Once there is a final court decision and proper civil registry annotation, the woman has a strong legal basis to request reversion to her maiden name on her Philippine passport.

The usual documentary requirements may include:

Final court decision;
Certificate of finality;
Annotated marriage certificate;
Annotated birth certificate, if applicable;
Valid IDs;
Current or expired passport;
Other DFA-required documents.

The important point is that the name reversion is supported by a legal change in civil status or legal recognition that the marriage no longer produces the same surname consequences.

VI. Death of the Husband

If the husband has died, the surviving spouse may generally have a recognized basis to revert to maiden surname, subject to documentary requirements.

Documents may include:

Death certificate of the husband;
Marriage certificate;
Birth certificate of the applicant;
Current passport;
Valid IDs;
Other required documents.

The widow may choose to continue using the married surname or request reversion, depending on applicable rules and documentation.

VII. Recognition of Foreign Divorce

Foreign divorce issues are especially important for Filipinos.

A. Divorce obtained by foreign spouse

If a Filipino is married to a foreigner and the foreign spouse obtains a valid divorce abroad that allows the foreign spouse to remarry, Philippine law may allow the Filipino spouse to have that divorce judicially recognized in the Philippines.

Once the foreign divorce is judicially recognized and properly annotated in the civil registry, the Filipino spouse may have a basis to update civil status and request passport name reversion.

B. Divorce obtained by a former Filipino who later became foreign citizen

There are cases where one spouse becomes a foreign citizen and obtains divorce abroad. Recognition may be necessary before Philippine records are changed.

C. Divorce between two Filipinos abroad

As a general principle, divorce between two Filipinos is not automatically recognized in the Philippines merely because it was obtained abroad. The facts matter, especially citizenship at the time of divorce and applicable law.

D. Passport effect

For passport purposes, a foreign divorce document alone may not be enough. Philippine authorities generally require recognition by a Philippine court and annotation in civil registry records before using it as basis for changes in civil status or surname.

VIII. What If the Marriage Certificate Is Not Yet Reported or Registered?

Some Filipinos marry abroad and do not immediately report the marriage to the Philippine Embassy, Consulate, or civil registry. They may still hold a Philippine passport under their maiden name.

If the passport has never been changed to the married surname, the person may often continue using the maiden name. However, failure to report a marriage may have separate civil registry consequences.

If the person later reports the marriage and chooses to use the married surname, then future reversion may require a recognized legal basis.

The practical point is:

Keeping a maiden-name passport after marriage is different from reverting after already changing to a married-name passport.

IX. What If the Passport Was Changed to Married Name by Mistake?

Sometimes a married woman may say that she was pressured, misinformed, or mistakenly believed she was required to use her husband’s surname.

In practice, once the passport has already been issued under the married surname, correction may be difficult without legal basis. DFA may treat the change as an election to use the married surname.

A claim of mistake may require strong proof and may still not be accepted as a simple administrative correction if the married name was based on a valid marriage certificate and proper application.

If there was a clerical error, typographical error, or mismatch unrelated to the voluntary use of married surname, that is a different matter. Clerical correction may be handled through appropriate civil registry and passport correction procedures.

X. What If the Woman Never Wanted to Use Her Husband’s Surname?

A married woman is not legally required to use her husband’s surname in every context. She may retain her maiden name in professional, business, or personal use, subject to consistency in official records.

For passport purposes, however, the controlling issue is what appears in the passport record and what documentary basis exists for changing it.

If she has not yet changed her passport to the married surname, she should think carefully before doing so. Once changed, reverting is not usually allowed merely because she later prefers the maiden name.

XI. Difference Between Passport, IDs, Bank Records, and Professional Records

A person’s name may appear differently across institutions. For example:

Passport: married surname;
PRC ID: maiden surname;
Bank account: married surname;
Employment records: maiden surname;
SSS or GSIS: married surname;
PhilHealth: married surname;
School records: maiden surname.

This creates practical problems.

Government agencies and private institutions may have their own documentary requirements. Some may allow continued use of maiden name more easily than others. But the Philippine passport is particularly strict because it is an identity and travel document.

A person should avoid casually switching between names without understanding the consequences. Inconsistent records may cause issues in:

International travel;
Visa applications;
Immigration processing;
Overseas employment;
Bank transactions;
Property transactions;
School records;
Professional licensing;
Inheritance and succession matters;
Children’s records.

XII. Can a Married Man Revert to a “Maiden Name”?

Strictly speaking, “maiden name” usually refers to a woman’s surname before marriage. Under Philippine naming customs and law, men generally do not change surnames upon marriage.

However, if a married person legally changed name through court order or other legal process and later wants to revert, the issue would depend on the nature of the name change and the documentary basis.

For most Philippine passport discussions, the issue concerns married women who used the husband’s surname and later want to return to their maiden surname.

XIII. Is a Court Order Always Required?

Not always. The legal basis may be established through documents depending on the ground.

For example:

Death of spouse may be supported by a death certificate.
Annulment or nullity requires court documents and civil registry annotation.
Recognition of foreign divorce requires court recognition and annotation.
Clerical errors may require civil registry correction documents.
Change of name may require court order, depending on the case.

For a married woman whose marriage is still valid and who simply wants to use her maiden surname again after already adopting the married surname on the passport, there is generally no simple administrative shortcut.

XIV. Does the Constitution or Gender Equality Allow Reversion Without Annulment?

One may argue that because a married woman is not required by law to use her husband’s surname, she should be allowed to revert to her maiden name based on personal choice.

This is a serious policy argument. It is based on identity, equality, autonomy, and the optional character of the married surname under civil law.

However, passport administration follows official documentary identity records. The DFA generally prioritizes consistency, fraud prevention, civil registry status, and documentary basis. Once a passport record has been changed to the married surname, the agency may require a legally recognized event before allowing reversion.

Thus, while gender equality supports the right not to adopt the married surname in the first place, it does not necessarily mean unrestricted administrative switching after adoption of the married surname in a passport.

XV. Practical Rule for Married Women Applying for a Passport

A married woman should decide carefully before changing her passport surname.

A. If she wants to keep her maiden surname

She should renew or apply under her maiden name, if allowed by her records and passport history. She should avoid changing to her married surname unless she is sure she wants to use it long-term.

B. If she wants to use her married surname

She should submit the marriage certificate and comply with DFA requirements. Once the passport is issued under the married surname, future reversion will likely require a legal basis.

C. If she is unsure

It is usually safer to keep the maiden surname until she is certain. Changing to married surname may create long-term administrative consequences.

XVI. Common Situations and Likely Outcomes

Situation 1: Married woman never changed passport to married surname

She may generally continue using her maiden surname on her passport.

Situation 2: Married woman changed passport to married surname and now wants maiden name again

Generally not allowed without recognized legal basis such as annulment, nullity, recognized divorce, or death of spouse.

Situation 3: Married woman is separated-in-fact

Separation-in-fact is generally not enough.

Situation 4: Married woman has a legal separation decree

Legal separation does not dissolve marriage. It may not be enough by itself for passport reversion.

Situation 5: Husband died

Reversion may generally be allowed upon submission of required death and civil registry documents.

Situation 6: Marriage annulled

Reversion may generally be allowed with final court decision, certificate of finality, and annotated civil registry documents.

Situation 7: Marriage declared void

Reversion may generally be allowed with final court decision, certificate of finality, and annotated documents.

Situation 8: Foreign divorce recognized by Philippine court

Reversion may generally be allowed after recognition and proper annotation.

Situation 9: Foreign divorce not yet recognized

The divorce document alone may not be enough for passport reversion.

Situation 10: Married woman says she never legally changed her name, only passport changed

Passport authorities may still treat the prior passport change as controlling unless a recognized ground for reversion exists.

XVII. Required Documents Commonly Involved

The exact requirements may depend on the DFA office, the applicant’s records, and the legal ground. Commonly relevant documents include:

Current or expired Philippine passport;
PSA-issued birth certificate;
PSA-issued marriage certificate;
Valid government-issued IDs;
Death certificate of spouse, if widow;
Court decision for annulment or declaration of nullity;
Certificate of finality;
Annotated marriage certificate;
Annotated birth certificate, where applicable;
Judicial recognition of foreign divorce, if applicable;
Foreign divorce decree and official documents, if relevant;
Report of Marriage, if married abroad;
Other documents required by DFA.

The most important evidence is the document showing the legal basis for reversion.

XVIII. What If the Applicant Needs to Travel Urgently?

Urgent travel does not usually create a legal basis for surname reversion. If there is no recognized ground, the applicant may need to renew using the surname currently reflected in passport records.

If the person has travel documents, visas, tickets, residence permits, or work documents under different names, she should resolve the inconsistency early. Airlines, immigration authorities, embassies, and foreign agencies may require consistency between passport and supporting documents.

XIX. What If the Visa or Foreign Residence Card Uses the Maiden Name?

This can create complications. The Philippine passport is the primary travel identity document. If the visa, residence card, employment permit, or foreign document uses the maiden name while the passport uses the married surname, the applicant may need to present supporting documents proving that both names refer to the same person.

These may include:

Birth certificate;
Marriage certificate;
Old passport;
Government IDs;
Affidavit of one and the same person, where accepted;
Foreign immigration records;
Court or civil registry documents, if applicable.

However, an affidavit of one and the same person does not usually create authority to change the passport name back to maiden surname. It only helps explain identity discrepancies.

XX. Can an Affidavit Allow Reversion to Maiden Name?

Usually, no.

An affidavit may explain facts, but it does not dissolve a marriage, annul a marriage, recognize a foreign divorce, or change civil status.

An affidavit of request, affidavit of election, affidavit of non-use, or affidavit of one and the same person may not be enough to compel passport reversion if the passport is already under the married surname and the marriage remains valid.

A government agency usually requires primary legal documents, not merely personal declarations, for major name changes.

XXI. Can the Husband Consent to the Reversion?

A husband’s consent is generally not the controlling issue. A married woman’s name is not owned by the husband. However, the problem is the passport authority’s rules and the legal status of the marriage.

Even if the husband signs a consent, waiver, or affidavit saying the wife may use her maiden name, that does not necessarily provide a legal basis for DFA to revert the passport surname.

The legal issue is not spousal permission. It is documentary authority for changing passport records.

XXII. Can a Married Woman Use Her Maiden Name in Daily Life While Passport Shows Married Name?

Yes, in many situations, a married woman may continue using her maiden name socially, professionally, or commercially, depending on the context and institutional requirements.

However, for transactions requiring a passport, the passport name controls. If other records use the maiden name, the person may need to present documents showing identity continuity.

The practical risk is inconsistency. The more official records differ, the more likely the person will encounter administrative delays.

XXIII. Professional Use of Maiden Name

Many married women continue using their maiden name professionally, especially lawyers, doctors, accountants, academics, artists, public officials, and business owners.

Professional use of a maiden name does not necessarily mean the passport can be administratively reverted if it already bears the married surname. Professional records and passport records are governed by different agencies and rules.

A professional may need supporting documents to reconcile records, especially for foreign travel, employment, licensure, contracts, or banking.

XXIV. Children’s Records and Mother’s Name

A mother’s name in a child’s birth certificate may appear in a particular format depending on civil registry practice. Reverting or not reverting the mother’s passport surname does not erase her identity as the child’s mother.

However, when traveling with children, especially internationally, name discrepancies may require supporting documents such as birth certificates, marriage certificates, old passports, or affidavits.

XXV. Marriage Abroad and Report of Marriage

A Filipino married abroad should generally report the marriage to the Philippine Embassy or Consulate for civil registry purposes.

If the passport remains in the maiden name and the person later reports the marriage, she should be careful whether she requests a passport amendment or renewal using the married surname.

Once she chooses the married surname in a Philippine passport, later reversion may require the same legal grounds discussed above.

XXVI. Annulment Pending: Can the Applicant Revert While the Case Is Ongoing?

Usually, no. A pending annulment or nullity case does not yet dissolve or nullify the marriage for passport purposes.

Until there is a final decision, certificate of finality, and proper civil registry annotation, the applicant generally remains married in official records.

A pending case may explain the situation, but it is not usually enough to revert the passport surname.

XXVII. Foreign Divorce Pending Recognition: Can the Applicant Revert?

Usually, no. A foreign divorce may need judicial recognition in the Philippines before Philippine civil registry and passport records can be changed.

Until recognition and annotation are completed, the DFA may continue to rely on existing Philippine civil registry records.

XXVIII. Widowhood Versus Annulment Versus Divorce Recognition

These grounds differ but may all support reversion if properly documented.

A. Widowhood

The marriage ended by death. Death certificate is central.

B. Annulment or nullity

The marriage is dissolved or declared void by court judgment. Court decision, finality, and annotation are central.

C. Recognition of foreign divorce

A foreign divorce is given effect in the Philippines through judicial recognition. Recognition judgment and annotation are central.

Each requires documents. Personal preference alone is not enough.

XXIX. What If the Marriage Was Void From the Beginning?

Even if a marriage is legally void, a person cannot simply declare it void for passport purposes. A court declaration is generally required for official recognition and civil registry changes.

For example, if a woman believes her marriage is void because of bigamy, lack of license, psychological incapacity, or other grounds, she still generally needs a court judgment before the DFA treats the marriage as legally nullified for name reversion purposes.

XXX. What If the Husband Abandoned the Wife?

Abandonment is painful and may have legal consequences in support, property, VAWC, custody, or criminal contexts depending on the facts. But abandonment alone does not dissolve marriage.

Therefore, abandonment by itself is generally not enough to revert to maiden name on a Philippine passport if the passport already uses the married surname.

The wife may need to pursue the appropriate legal remedy, such as annulment, declaration of nullity, legal separation, support, protection order, or other case depending on facts. But for passport surname reversion, the recognized grounds remain limited.

XXXI. What If the Husband Is Missing?

If the husband is missing, the marriage is not automatically dissolved. There are legal processes involving presumptive death in certain circumstances, usually for purposes such as remarriage, but this is fact-specific and requires court proceedings.

For passport reversion, a missing spouse situation may not be enough without a recognized civil registry or court document accepted by DFA.

XXXII. What If the Applicant Is a Victim of Abuse?

A victim of abuse may have remedies under laws such as the Anti-Violence Against Women and Their Children Act, protection orders, criminal complaints, support actions, custody remedies, legal separation, annulment, or declaration of nullity depending on the facts.

However, abuse by itself may not automatically authorize passport reversion to maiden name if the marriage remains legally subsisting and the passport already uses the married surname.

That said, safety concerns may support urgent legal action and protective measures. The name issue may be part of a broader legal strategy.

XXXIII. What If the Applicant Has a Foreign Passport Under Maiden Name?

Dual citizens or persons with foreign documents may have mismatched names across jurisdictions. A foreign passport under the maiden name does not automatically require the Philippine passport to revert if Philippine passport records already show the married surname.

The applicant may need to reconcile records through civil registry documents, court orders, or foreign legal documents accepted by Philippine authorities.

XXXIV. Can the Applicant File a Court Petition to Change Name?

A court petition for change of name may be possible in certain circumstances, but it is not a simple substitute for annulment or divorce recognition. Courts do not grant name changes casually. There must be proper grounds, procedure, publication where required, and proof.

If the desired change is essentially tied to marital status, the court may consider whether the proper remedy is annulment, nullity, recognition of divorce, correction of civil registry, or another action.

A change-of-name petition may be complex and should be evaluated carefully by counsel.

XXXV. Legal Policy Behind Strict Passport Reversion Rules

The strict approach exists for several reasons:

Passport integrity;
Prevention of identity fraud;
Consistency with civil registry records;
Avoidance of repeated name switching;
International travel security;
Reliance by foreign governments on passport identity;
Administrative certainty;
Consistency between civil status and documentary identity.

While a married woman’s use of the husband’s surname may be optional in civil law, passport authorities still require stable and verifiable identity records.

XXXVI. Practical Problems Caused by Changing to Married Name

Changing a passport to married surname may affect:

Visas;
Airline tickets;
Overseas employment contracts;
Foreign residence cards;
Bank accounts;
PRC or professional licenses;
School records;
Property titles;
Tax records;
Social security records;
Insurance policies;
Children’s travel documents.

Before changing to married name, a woman should consider the cost and effort of updating all related records.

XXXVII. Practical Problems Caused by Inconsistent Names

If a person uses maiden name in some records and married name in others, she may encounter:

Delayed passport processing;
Visa complications;
Immigration questioning;
Bank compliance issues;
Difficulty proving identity;
Problems claiming benefits;
Issues with school or employment records;
Difficulty selling property;
Confusion in legal documents;
Need for repeated affidavits and supporting documents.

Consistency is often more important than preference in official transactions.

XXXVIII. Recommended Approach Before Applying

Before applying for a passport renewal or amendment, the applicant should:

Identify the exact name in the current passport;
Check the name in the PSA birth certificate;
Check the name in the PSA marriage certificate;
Determine whether the married surname has already been used in a Philippine passport;
Identify whether there is a legal ground for reversion;
Prepare required supporting documents;
Check consistency with visas and travel records;
Avoid booking international travel until name issues are resolved;
Seek legal advice if annulment, nullity, divorce recognition, or correction is involved.

XXXIX. Practical Examples

Example 1: Married but passport still in maiden name

Maria Santos married Juan Cruz. Her passport still says Maria Santos. She has never used Maria Cruz in her passport.

She may generally renew under Maria Santos, subject to requirements.

Example 2: Married surname already used

Maria Santos married Juan Cruz and changed her passport to Maria Cruz. Later, she separated from Juan but has no annulment.

She generally cannot simply request that the passport go back to Maria Santos.

Example 3: Annulment granted

Maria obtained a final annulment judgment, certificate of finality, and annotated marriage certificate.

She may request reversion to maiden name with proper documents.

Example 4: Husband died

Maria’s husband died. She has the death certificate and supporting civil registry documents.

She may request reversion, subject to DFA requirements.

Example 5: Foreign divorce not recognized

Maria’s foreign husband divorced her abroad, but she has not obtained Philippine judicial recognition.

The foreign divorce decree alone may not be enough for Philippine passport reversion.

Example 6: Legal separation

Maria obtained legal separation from Juan but remains legally married.

Reversion may still be problematic because legal separation does not dissolve marriage.

XL. Frequently Asked Questions

1. Can a married woman keep her maiden name on her Philippine passport?

Yes, if she has not changed her passport to her married surname, she may generally continue using her maiden name.

2. Can she revert to maiden name after already using her husband’s surname?

Generally, not without a recognized legal basis such as annulment, declaration of nullity, death of spouse, or recognized foreign divorce.

3. Is annulment required?

Annulment is one possible ground. Other grounds may include declaration of nullity, death of spouse, or recognized foreign divorce. But if the marriage remains valid and subsisting, reversion is generally not allowed after the married surname has been used.

4. Is separation-in-fact enough?

No. Separation-in-fact does not dissolve the marriage.

5. Is legal separation enough?

Legal separation does not dissolve the marriage. It may not be sufficient for passport reversion.

6. Can the husband give consent?

The husband’s consent is not usually enough. The issue is legal basis and passport records, not spousal permission.

7. Can an affidavit allow reversion?

Usually, no. An affidavit cannot replace annulment, nullity, recognized divorce, death certificate, or required civil registry documents.

8. What if she was forced or pressured to use the married surname?

That may explain the situation, but once the passport has been issued under the married surname, DFA may still require a recognized legal basis for reversion.

9. Can she use maiden name professionally while passport uses married name?

Yes, in many contexts, but official transactions may require proof that both names refer to the same person.

10. Should a newly married woman change her passport to married name?

Only if she is sure. If she wants flexibility and continuity, keeping the maiden surname may be simpler.

XLI. Conclusion

A married woman in the Philippines is not automatically required to use her husband’s surname. She may generally keep using her maiden name, including on her passport, if she has not previously changed her passport to the married surname.

The more difficult issue arises when she has already used the husband’s surname in a Philippine passport. In that case, she generally cannot revert to her maiden name merely because she prefers it, is separated-in-fact, has marital problems, or wants consistency with professional records. The Department of Foreign Affairs usually requires a recognized legal basis.

The usual grounds for reversion include:

Death of the husband;
Annulment of marriage;
Declaration of nullity of marriage;
Judicial recognition of foreign divorce;
Other court or civil registry basis accepted by passport authorities.

Without annulment or another legally recognized ground, a married woman whose Philippine passport already bears her married surname will generally have difficulty reverting to her maiden surname.

The practical lesson is clear: a married woman should think carefully before changing her Philippine passport to her married surname. Keeping the maiden name is often easier than changing to married name and later trying to revert.