Case Digest (G.R. No. 132244)
Facts:
The case involves Gerardo Angat, the petitioner, against the Republic of the Philippines, the respondent, with the decision rendered by the Supreme Court on September 14, 1999. Gerardo Angat was a natural-born citizen of the Philippines who lost his citizenship due to naturalization in the United States. He resided at No. 69 New York Street, Provident Village, Marikina City. On March 11, 1996, Angat filed a petition with the Regional Trial Court (RTC) of Marikina City, Branch 272, seeking to regain his Philippine citizenship under Commonwealth Act No. 63, Republic Act No. 965, and Republic Act No. 2630. In his petition, he provided details about his identity, residence, profession, marital status, and qualifications for reacquiring citizenship, asserting that he had not committed any disqualifying acts and had resided in the Philippines since 1991.
The RTC initially set a hearing for January 27, 1997, and on June 13, 1996, Angat sought permission to take his oath of allegia...
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:
- Personal Information: His full name, date and place of birth, and marital status.
- Residence: His current residence in Marikina and former residence in Las Vegas, U.S.A.
- Occupation: Engaged in buy-and-sell businesses and managing his parents' properties.
- Citizenship: He was born in the Philippines, lost citizenship by U.S. naturalization, and is currently a U.S. citizen.
- Qualifications: Claimed to meet all qualifications under the laws cited and stated he had no disqualifications.
- 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:
- Whether the RTC had jurisdiction over Angat’s petition for repatriation.
- 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.