Quilala v. Reyes
REITERATIONFacts
The Antecedents: Petitioner Oscar R. Quilala, born in 1947 to a Filipino mother and an American father, was admitted to the Philippine Bar in 1971 after passing the 1970 Bar Examinations. His admission was conditioned on submitting proof of cancellation of his alien certificate of registration. Procedural History: In 1973, the Undersecretary of Justice disallowed the cancellation of petitioner's alien registry, citing insufficient evidence of his mother's Filipino citizenship prior to marriage. Consequently, this Court ordered the cancellation of petitioner's name from the Roll of Attorneys in 1976. Petitioner later left for the United States and upon returning, sought reconsideration of the denial of his citizenship election. The Petition: Petitioner filed a petition for reinstatement in the Roll of Attorneys and for re-admission to the practice of law. He argued that his roots, upbringing, education, and professional training were Filipino, and that he had elected Philippine citizenship upon reaching the age of majority. He also presented additional documents to support his claim and moved for reconsideration of the denial of his citizenship election.
Issue(s)
Whether the petitioner, born of a Filipino mother and an American father, validly elected Philippine citizenship. Whether the cancellation of the petitioner's alien certificate of registration was properly ordered, thereby removing the obstacle to his admission to the Philippine Bar and reinstatement to the Roll of Attorneys.
Ruling
The petition is granted. Petitioner is allowed to be reinstated in the roll of attorneys and to be re-admitted to the practice of law in the Philippines.
Ratio Decidendi
On Issue 1: The Court found that the petitioner, born on May 27, 1947, in Manila, was the legitimate child of Pelagio P. Quilala, an American citizen, and Julia Ramos, a Filipino citizen prior to her marriage. The Court affirmed that petitioner had the right to elect Philippine citizenship upon reaching the age of majority, which he did on May 26, 1970, at the age of 23 years. His oath of allegiance to the Republic of the Philippines was taken on the same day and duly registered in the Office of the Local Civil Registrar of Quezon City on May 28, 1970. The Court considered these actions as a valid exercise of his right to elect Philippine citizenship under the 1935 Constitution, Article IV, Section 1(4), in relation to the 1973 Constitution, Article III, Section 1(3), and Commonwealth Act No. 625. On Issue 2: The Court noted that the Undersecretary of Justice, upon reconsideration and submission of additional documents, affirmed the order of the Commissioner of Immigration and Deportation dated March 5, 1971, which granted the cancellation of the petitioner's alien certificate of registration. This reconsideration and affirmation removed the legal obstacle to the petitioner becoming a Filipino citizen and, consequently, to his admission to the Philippine Bar and reinstatement to the Roll of Attorneys. The Court found no further legal impediment to his status as a Filipino citizen, thus allowing his petition for reinstatement.
Main Doctrine
The right of a person born of a Filipino mother and a foreign father to elect Philippine citizenship upon reaching the age of majority is a fundamental right, provided it is exercised in accordance with constitutional and statutory requirements. The validity of this election, including the cancellation of any alien certificate of registration, is crucial for admission to the Philippine Bar and the practice of law. Reinstatement to the Roll of Attorneys is contingent upon the resolution of any issues pertaining to citizenship and the removal of disqualifications.