Angat v. Republic of the Philippines
REITERATIONFacts
The Antecedents: Petitioner Gerardo Angat, a natural-born Filipino citizen, lost his citizenship upon naturalizing as a citizen of the United States of America. He returned to the Philippines in 1991 and engaged in business and property management. Angat sought to reacquire his Philippine citizenship. Procedural History: Angat filed a petition to reacquire his citizenship with the Regional Trial Court (RTC) of Marikina City on March 11, 1996. The RTC initially granted his petition, allowing him to take an oath of allegiance on October 3, 1996, and subsequently issued an order on October 4, 1996, repatriating him and declaring him a Filipino citizen. However, the Office of the Solicitor General (OSG) filed a motion to dismiss, arguing the RTC lacked jurisdiction and that the petition should have been filed with the Special Committee on Naturalization. The RTC granted this motion in an order dated September 22, 1997, setting aside its previous orders and dismissing Angat's petition for lack of jurisdiction. Angat's motion for reconsideration was denied by the RTC in an order dated December 29, 1997. The Petition: This case is an appeal by certiorari under Rule 45 of the Rules of Civil Procedure. Angat argues that the RTC erred in dismissing his petition by giving retroactive effect to Administrative Order No. 285, which established the Special Committee on Naturalization as the implementing agency for Republic Act No. 8171. He contends that since his petition was filed before the Special Committee was constituted, the RTC had jurisdiction. The OSG maintains that the RTC lacked jurisdiction because the Special Committee on Naturalization, established under Presidential Decree No. 725 and reactivated prior to Angat's petition, was the proper forum for reacquisition of citizenship under R.A. 8171.
Issue(s)
Whether the Regional Trial Court had jurisdiction to entertain the petition for repatriation filed by Gerardo Angat. Whether Administrative Order No. 285 could be given retroactive effect to divest the RTC of jurisdiction over a petition filed prior to its issuance, considering the Special Committee on Naturalization's reactivation.
Ruling
The petition for review is denied, and the order of the Regional Trial Court dated September 22, 1997, dismissing the petition for want of jurisdiction, is affirmed.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court: The Supreme Court affirmed the RTC's dismissal for lack of jurisdiction. Republic Act No. 8171 mandates that repatriation applications be processed by the Special Committee on Naturalization, which was already in place and functioning when Angat filed his petition. Therefore, the RTC erred in taking cognizance of the petition, as the proper forum was the Special Committee on Naturalization. On the retroactive application of Administrative Order No. 285: The Court found the petitioner's contention to be without merit. While AO 285 was promulgated after the petition was filed, the Special Committee on Naturalization was already in existence and operational since its reactivation. The issuance of AO 285 was merely a confirmatory issuance. Jurisdiction over repatriation cases under R.A. 8171 was vested in the Special Committee on Naturalization, not the RTC, from the time the committee was reactivated. Therefore, the RTC's order granting repatriation was null and void from the beginning due to lack of jurisdiction.
Main Doctrine
A petition for repatriation under Republic Act No. 8171 must be filed with the Special Committee on Naturalization, not the Regional Trial Court, if the Special Committee has already been constituted.