Title
Angat vs. Republic
Case
G.R. No. 132244
Decision Date
Sep 14, 1999
Gerardo Angat, a natural-born Filipino who lost citizenship via U.S. naturalization, sought repatriation under Philippine law. The Supreme Court ruled the RTC lacked jurisdiction, affirming petitions must be filed with the Special Committee on Naturalization, rendering prior RTC orders void.
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Case Digest (G.R. No. 132244)

Facts:

Background and Citizenship Loss

Petitioner Gerardo Angat was a natural-born citizen of the Philippines who lost his Philippine citizenship after naturalizing in the United States of America. He returned to the Philippines in 1991 and resided in Marikina City. On March 11, 1996, he filed a petition before the Regional Trial Court (RTC) of Marikina City to reacquire his Philippine citizenship under Commonwealth Act No. 63, as amended, and Republic Acts (R.A.) Nos. 965 and 2630.

Petition Details

In his petition, Angat provided the following details:

  1. Personal Information: His full name, date and place of birth, and marital status.
  2. Residence: His current residence in Marikina and former residence in Las Vegas, U.S.A.
  3. Occupation: Engaged in buy-and-sell businesses and managing his parents' properties.
  4. Citizenship: He was born in the Philippines, lost citizenship by U.S. naturalization, and is currently a U.S. citizen.
  5. Qualifications: Claimed to meet all qualifications under the laws cited and stated he had no disqualifications.
  6. Intentions: Expressed his intention to reacquire Philippine citizenship and renounce allegiance to the U.S.

Initial Court Proceedings

The RTC initially set the case for hearing on January 27, 1997. Angat filed several motions, including one to take the oath of allegiance under R.A. 8171. The court initially denied this motion but later granted reconsideration, allowing Angat to take the oath on October 3, 1996. On October 4, 1996, the court declared Angat repatriated as a Philippine citizen.

Solicitor General's Intervention

On March 19, 1997, the Office of the Solicitor General (OSG) filed a motion to dismiss the petition, arguing that the RTC lacked jurisdiction. The OSG contended that under Administrative Order (A.O.) No. 285, issued on August 22, 1996, petitions for repatriation should be filed with the Special Committee on Naturalization, not the RTC. The trial court agreed, dismissed the petition on September 22, 1997, and set aside its previous orders. Angat’s motion for reconsideration was denied on December 29, 1997.

Issue:

  1. Whether the RTC had jurisdiction over Angat’s petition for repatriation.
  2. Whether Administrative Order No. 285 could be applied retroactively to dismiss the petition.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court affirmed the RTC’s dismissal of Angat’s petition, holding that the Special Committee on Naturalization was the proper forum for his petition for repatriation. The RTC’s orders were null and void for lack of jurisdiction.


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