Lao Eng Guan v. Republic
REITERATIONFacts
The Antecedents: Petitioner-appellee Lao Eng Guan applied for naturalization. The Republic of the Philippines appealed the decision of the Court of First Instance of Zambales, Branch 1, which granted the application, arguing that the lower court erred in granting the application despite the failure to allege good moral character and in considering the increase in income after filing as curative for the insufficient income at the start of the proceedings. Procedural History: The Court of First Instance of Zambales granted the application for naturalization. The Republic of the Philippines appealed this decision to the Supreme Court. The Appeal: The Republic of the Philippines appealed the decision of the Court of First Instance of Zambales, Third Judicial District, Branch 1, dated December 24, 1968, which granted Philippine Citizenship to Lao Eng Guan. The grounds for appeal included the failure to allege good moral character and the curative effect given to an increase in income after the filing of the application, which was below the required level at the commencement of the proceedings, contrary to established precedents.
Issue(s)
Whether the appeal is moot and academic due to the petitioner-appellee being granted Philippine Citizenship during the pendency of the appeal.
Ruling
The appeal was deemed withdrawn and the case was dismissed for being moot and academic. No costs were awarded.
Ratio Decidendi
On Issue 1: The Supreme Court considered the manifestation and motion filed by the Republic of the Philippines on March 6, 1981, alleging that Lao Eng Guan was granted Philippine Citizenship on February 9, 1976, pursuant to Presidential Decree No. 836. Given this supervening event, the Court found the Republic's plea to dismiss the case as moot and academic to be warranted, as the subsequent grant of citizenship rendered the original appeal concerning the lower court's decision moot and academic. Therefore, the appeal was deemed withdrawn and the case was dismissed.
Main Doctrine
The Supreme Court dismissed the appeal in a naturalization case as moot and academic because the petitioner-appellee had already been granted Philippine citizenship during the pendency of the appeal through a Presidential Decree, rendering the original appeal concerning the lower court's decision moot.