Santos Co v. Government of the Philippine Islands
REITERATIONFacts
The Antecedents: Basilio Santos Co filed an application for Philippine citizenship under Act No. 2927. He alleged to be born in Malolos, Bulacan, in June 1890, to a Filipino mother and an unknown father. He claimed he did not become a Chinese citizen during his visits to China. He left for China with his parents in 1894 or 1895, returned to the Philippines in 1916, went back to China for treatment in the same year, returned to Manila in 1917, vacationed in China in 1922, and returned to Manila in 1923, remaining thereafter. Procedural History: The evidence presented included a baptismal certificate dated June 4, 1890, for a child named Basilio, born on the 10th of the month in Malolos, Bulacan, to Venancia Santos and an unknown father. The applicant testified that this certificate referred to him and that his mother had informed him of his birth in Malolos. The court below found the evidence insufficient to prove the applicant's birth in the Philippines and his Philippine origin, thus denying the application. The Petition: The applicant appealed the denial of his application for Philippine citizenship.
Issue(s)
Whether the applicant is a Philippine citizen by birth. Whether the naturalization proceedings under Act No. 2927 apply to individuals who are already Philippine citizens.
Ruling
The judgment of the court below denying the application for Philippine citizenship is affirmed. The Court held that the naturalization proceedings established by Act No. 2927 are not applicable to individuals who are already Philippine citizens by birth.
Ratio Decidendi
On the issue of Philippine citizenship by birth: The Court considered the applicant's contention that he is a Filipino citizen, born in the Philippines to a Filipino mother during the Spanish sovereignty, with an unknown father. The evidence presented, including the baptismal certificate and the applicant's testimony, aimed to establish these facts. However, the court below found this evidence unsatisfactory to prove his birth in the country and his Philippine origin. The Supreme Court, in affirming the lower court's decision, implicitly agreed that the evidence did not conclusively establish his birth in the Philippines as required for naturalization under Act No. 2927, or that he was already a citizen by operation of law. On the applicability of naturalization proceedings under Act No. 2927: The Court stated that if the applicant is indeed a Philippine citizen, as he contends, then the naturalization proceedings established by Act No. 2927, which are intended for those who are not Philippine citizens, do not apply to him. Therefore, there would be no need to institute such an action. This principle is derived from the understanding that naturalization is a process for acquiring citizenship, not for confirming existing citizenship. The case of U.S. vs. Ong Tianse was cited, suggesting that birth in the Philippines during Spanish sovereignty to a Filipino mother, with an unknown or non-married father, would confer Philippine citizenship. If this were conclusively proven, the applicant would already be a citizen, rendering the naturalization process unnecessary and inapplicable.
Main Doctrine
An application for Philippine citizenship under Act No. 2927 is not applicable to individuals who are already considered Philippine citizens by birth, having been born in the Philippines to a Filipino mother during the Spanish sovereignty.