Reyes v. Deportation Board
REITERATIONFacts
The Antecedents: Petitioner Ramon Sia Reyes was charged before the respondent Deportation Board with having misrepresented himself as a Filipino citizen. The Board issued a resolution declaring petitioner a "resident Chinese national, subject to the jurisdiction of the Board and to deportation under Section 69 of the Revised Administrative Code, should it be finally determined in further proceedings before the Board that just and sufficient cause exists for his expulsion as an undesirable alien." Procedural History: Petitioner's motion for reconsideration was denied. He then filed a petition for certiorari and prohibition with the Court of First Instance of Manila, seeking to set aside the resolution. The CFI dismissed his petition. The Petition: Petitioner filed the instant petition for review before the Supreme Court, alleging that the respondent court erred in not holding that there is substantial evidence of his Filipino citizenship, in holding that judicial declarations of his Filipino citizenship and a resolution of the Deportation Board do not constitute res judicata, in not applying the principle of jus soli, and in not declaring him a Filipino citizen.
Issue(s)
Whether there is substantial evidence of petitioner's Filipino citizenship. Whether the principle of jus soli applies to petitioner. Whether the applicability of Roa vs. Collector of Customs applies to the petitioner. Whether judicial declarations of petitioner's Filipino citizenship constitute res judicata. Whether the resolution of the Deportation Board constitutes res judicata, and whether petitioner should be declared a Filipino citizen.
Ruling
The petition is devoid of merit and is hereby dismissed.
Ratio Decidendi
On the issue of substantial evidence of Filipino citizenship: The Court affirmed the findings of the respondent court that petitioner's parents were both Chinese subjects at the time of his birth. While his father was subsequently naturalized and he elected Filipino citizenship, such election was inefficacious as he was no longer a minor when his father was naturalized, and his mother was not a citizen of the Philippines at the relevant times. On the application of the principle of jus soli: The Court reiterated its ruling in Tan Chong vs. Secretary of Labor that the doctrine of jus soli was never extended to the Philippines, thus it cannot be applied to grant Filipino citizenship to the petitioner. On the applicability of Roa vs. Collector of Customs: The Court distinguished this case, noting that the ruling in Roa was predicated not solely on birth in the Philippines but also on the circumstance of being born of an alien father and a Filipina mother, which is not the situation here. On the issue of res judicata concerning judicial declarations of citizenship: The Court held that courts may make pronouncements relative to Filipino citizenship as an incident to the adjudication of other rights. However, such declarations, made as an incident, cannot have greater standing than proceedings where citizenship is the principal basis of the cause of action. The Court emphasized that a judgment in a naturalization proceeding is not afforded the character of impregnability under res judicata, and therefore, a declaration of citizenship made as an incident cannot be given greater force. On the issue of res judicata concerning the Deportation Board resolution, and whether petitioner should be declared a Filipino citizen: The Court reiterated that if a favorable judgment in a naturalization proceeding is not res judicata, then a pronouncement or declaration of Filipino citizenship made as a mere incident in the adjudication of rights certainly cannot be res judicata.
Main Doctrine
Judicial declarations of Filipino citizenship made as an incident in the determination of other rights do not constitute res judicata on the issue of citizenship, especially when compared to judgments in naturalization proceedings which are themselves not afforded the character of impregnability under the principle of res judicata.