Go v. Republic

G.R. No. L-39326 · 1976-06-03 · J. AQUINO, J.: · Primary: Civil; Secondary: Political
REITERATION

Facts

The Antecedents: Antonio K. Go filed a petition for naturalization. The Court of First Instance of Tarlac denied his petition. Procedural History: Go appealed the decision of the Court of First Instance to the Supreme Court. The Appeal: Go filed his appellant's brief. Subsequently, the Solicitor General filed a motion to suspend the period for filing the appellee's brief, citing Go's application for naturalization under Letter of Instructions No. 270. This motion was granted. Later, the Assistant Solicitor General informed the Court that Go's administrative application for naturalization under Letter of Instructions No. 270 had been approved, and he had taken his oath as a Filipino citizen on January 23, 1976, by virtue of Presidential Decree No. 836. He was issued Certificate of Naturalization No. 001067 dated February 25, 1976.

Issue(s)

Whether the appeal has become moot and academic due to the petitioner's subsequent naturalization.

Ruling

The appeal was dismissed for having become moot and academic. No costs were awarded.

Ratio Decidendi

On Whether the appeal has become moot and academic due to the petitioner's subsequent naturalization: The Court found that the appeal had indeed become moot and academic. The petitioner, Antonio K. Go, had pursued and successfully obtained naturalization as a Filipino citizen under Letter of Instructions No. 270. He had taken his oath of citizenship on January 23, 1976, and was issued a Certificate of Naturalization. This supervening event meant that the original petition for naturalization, which was the subject of the appeal, had been resolved in his favor through a separate administrative process. Consequently, there was no longer a practical or legal issue for the appellate court to resolve concerning the denial of his initial petition. The Court's duty is to decide actual controversies, and when the controversy ceases to exist, the case is dismissed as moot and academic. This aligns with the principle that courts should not render advisory opinions or pass upon abstract questions.

Main Doctrine

The Supreme Court dismissed the appeal for being moot and academic because the petitioner, Antonio K. Go, had already been granted naturalization under Letter of Instructions No. 270 and had taken his oath as a Filipino citizen. This supervening event rendered the appeal concerning the denial of his earlier naturalization petition moot and academic, as the issue of his citizenship had been resolved.

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