G.R. No. L-34100. June 30, 1976.
IN THE MATTER OF THE PETITION TO BE ADMITTED AS CITIZEN OF THE PHILIPPINES, CHAN YEN, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

This is an appeal from a decision of the then Court of First Instance, presided by Judge Jose N. Leuterio, denying the petition for naturalization filed by Chan Yen. The lower court denied the petition on the specific ground that Chan Yen failed to comply with the mandatory requirement of registering his children with the Bureau of Immigration within the first sixty days of every calendar year, as consistently required by jurisprudence. This failure cast serious doubt on his claim of having conducted himself in a proper and irreproachable manner in his relations with the government and the community throughout his residence in the Philippines, a statutory requirement for naturalization.
Subsequent to the filing of briefs by both the appellant and the appellee Republic, Chan Yen filed a Motion for Dismissal dated April 27, 1976. In this motion, he informed the Supreme Court that he had already been granted Philippine citizenship under Presidential Decree No. 836. He attached as evidence his Certificate of Naturalization No. 002505, issued by the Special Committee on Naturalization on February 24, 1976, and his Identification Certificate from the Commission on Immigration and Deportation. He prayed for the dismissal of his appeal on the ground that the issue had been rendered moot and academic by this subsequent grant of citizenship.

ISSUE

Whether the appeal from the denial of Chan Yen’s petition for naturalization should be dismissed as moot and academic.

RULING

Yes, the appeal is dismissed. The core legal principle applied is that courts will not determine cases where no actual controversy exists or where the issues have become academic. A case becomes moot and academic when, by virtue of supervening events, there is no more justiciable controversy to resolve, or when a judgment can no longer provide any practical relief or have any practical legal effect. In this instance, the supervening event is Chan Yen’s acquisition of Philippine citizenship through a different legal process—Presidential Decree No. 836—which established the Special Committee on Naturalization. His presentation of a valid Certificate of Naturalization and Identification Certificate conclusively demonstrates that he has already attained the very status he sought in his judicial petition. Therefore, a decision on the merits of his appeal regarding the lower court’s denial would be an exercise in futility, as it could not alter his current status as a naturalized citizen. The Supreme Court, recognizing this, granted the motion and dismissed the appeal, rendering no further adjudication on the propriety of the lower court’s initial denial necessary.