Yu Hio Soo v. Republic
REITERATIONFacts
The Antecedents: This case concerns a petition for naturalization filed by Yu Hio Soo, also known as William Kee Eng Hoc, seeking to be admitted as a citizen of the Philippines. The Republic of the Philippines, through the Solicitor General, opposed the petition. Procedural History: The petition was initially granted by the Court of First Instance, which declared Yu Hio Soo eligible for Philippine citizenship. The Republic of the Philippines appealed this decision to the Supreme Court, raising issues regarding the petitioner's alleged failure to demonstrate a lucrative income, his conduct, and the competency of his witnesses. The appeal was subsequently submitted for decision. The Petition: While the appeal was pending before the Supreme Court, the petitioner-appellee filed a motion to withdraw the case. He asserted that he had already been granted Filipino citizenship under Presidential Decree No. 836 and had taken his oath of allegiance on February 4, 1976, rendering the appeal moot and academic. The Solicitor General, in a subsequent manifestation, agreed to the dismissal of the case for the same reason, noting the petitioner's oath of allegiance taken on February 3, 1976, in connection with an approved application under Letter of Instruction No. 270.
Issue(s)
Whether the appeal filed by the Republic of the Philippines has become moot and academic.
Ruling
The Supreme Court dismissed the appeal filed by the Republic of the Philippines as moot and academic. No costs were awarded.
Ratio Decidendi
On Whether the appeal filed by the Republic of the Philippines has become moot and academic: The Supreme Court granted the motion to dismiss the appeal for being moot and academic. This was based on the manifestation of the petitioner-appellee that he had been granted Filipino citizenship under Presidential Decree No. 836 and had already taken his oath of allegiance on February 4, 1976. The oppositor-appellant, the Republic of the Philippines, through the Solicitor General, also manifested that it had no objection to the dismissal of the case for being moot and academic, citing the petitioner-appellee's approved application under Letter of Instruction No. 270 and his oath of allegiance taken on February 3, 1976. Consequently, the issues raised by the appellant in the appeal had become moot and academic due to these supervening events.
Main Doctrine
The Supreme Court dismissed the appeal filed by the Republic of the Philippines against the grant of citizenship to Yu Hio Soo because the petitioner-appellee had already taken his oath of allegiance as a Philippine citizen. This supervening event rendered the appeal moot and academic, as the core issue of eligibility for citizenship had been resolved by the petitioner's subsequent act of allegiance.