Ong v. Republic
REITERATIONFacts
The Antecedents: This case concerns a petition for naturalization filed by Benjamin Sun Ong. Procedural History: The Court of First Instance of Camarines Sur granted Benjamin Sun Ong's petition for naturalization in Naturalization Case No. 163. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Supreme Court. The Petition: The Solicitor General's appeal has been rendered moot and academic because Benjamin Sun Ong subsequently filed an application for naturalization under Letter of Instructions No. 270 and was issued Certificate of Naturalization No. 001164 on February 19, 1976.
Issue(s)
Whether the appeal from the grant of naturalization has become moot and academic.
Ruling
The appeal is dismissed for having become moot and academic. No costs.
Ratio Decidendi
On Issue 1: The appeal filed by the Solicitor General from the decision granting Benjamin Sun Ong's petition for naturalization was dismissed. The Solicitor General disclosed in a manifestation that Benjamin Sun Ong had filed an application for naturalization under Letter of Instructions No. 270 and that a Certificate of Naturalization No. 001164 was issued to him on February 19, 1976. Since the applicant had already been granted citizenship, the issue raised in the appeal, which was the propriety of granting the naturalization, had become moot and academic. The Court has consistently held that an appeal involving a naturalization case becomes moot and academic once the applicant has been granted citizenship. Therefore, the appeal was dismissed on this ground.
Main Doctrine
The appeal filed by the Solicitor General questioning the grant of naturalization to Benjamin Sun Ong was dismissed because the applicant had already been issued a Certificate of Naturalization. This subsequent event rendered the appeal moot and academic, as the primary issue of whether citizenship should be granted was already resolved by the issuance of the certificate.