G.R. No. L-19107-09 September 30, 1964
IN THE MATTER OF THE PETITIONS TO BE ADMITTED CITIZENS OF THE PHILIPPINES. LAO YAP HAN DIOK, LAO YAP HAN PICK alias ANTONIO LAO ROLIDA, FRANCISCO LAO ROLIDA alias LAO YAP KHING, petitioners-appellees, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Three separate petitions for naturalization were filed by appellees Lao Yap Han Diok, Antonio Lao Rolida, and Francisco Lao Rolida with the Court of First Instance of Maasin, Leyte. The petitions followed the prescribed form and contained the required allegations. The government filed a written opposition only against Lao Yap Han Diok’s petition, citing procedural defects, leading to its initial dismissal without prejudice. Subsequently, all three petitioners moved to dismiss their own petitions for naturalization. They instead requested the court to declare them Filipino citizens by birth, presenting baptismal certificates and birth records to prove their father, Pedro Rolida, was a Filipino. After hearings where Pedro Rolida testified, the lower court granted the motions. It dismissed the naturalization petitions as unnecessary and issued separate declarations that each petitioner was already a Filipino citizen from birth.

ISSUE

Whether the trial court, in a proceeding originally initiated as a petition for naturalization, has the judicial power to issue a declaratory judgment recognizing the petitioner as a Filipino citizen by birth.

RULING

No. The Supreme Court reversed the portion of the lower court’s decisions declaring the petitioners as Filipino citizens. The Court held that a judicial declaration of citizenship cannot be made within the context of a naturalization petition. Courts exist to settle justiciable controversies involving a legally demandable right, an act violating that right, and a legal remedy for the breach. A declaration of citizenship is not itself a justiciable controversy but may be made only as an incidental finding necessary to adjudicate an actual dispute. While the law provides a judicial process for acquiring citizenship through naturalization, there is no parallel legislation authorizing a judicial proceeding solely to declare an individual’s pre-existing citizenship status. The pronouncement in the Paralan v. Republic case, which overruled prior contrary doctrines, was controlling. Therefore, the trial court acted beyond its judicial power in making the declaratory ruling. The Supreme Court affirmed the dismissal of the naturalization petitions but set aside the declarations of Filipino citizenship.