Title
Chiongbian vs. De Leon
Case
G.R. No. L-2007
Decision Date
Jan 31, 1949
William Chiongbian, deemed a Filipino citizen under the 1935 Constitution, successfully challenged the cancellation of his vessels' registration and the rescission of their sale, affirming citizenship transmission from his father.

Case Digest (G.R. No. L-2007)
Expanded Legal Reasoning Model

Facts:

  • Parties and Context
    • Petitioner: William Chiongbian, owner of three vessels registered under Philippine registry.
    • Respondents: Alfredo De Leon (Commissioner of Customs), Jose Gallofin (Collector of Customs of the Port of Cebu), Vicente De La Cruz (General Manager of the Philippine Shipping Administration).
    • Intervenor: Philippine Shipowners’ Association.
  • Nature of the Petition
    • Petitioner sought a writ of prohibition to prevent:
      • Respondent Customs officials from cancelling the registration certificates of petitioner’s vessels.
      • Philippine Shipping Administration from rescinding the sale of three vessels to petitioner.
    • Respondents and Intervenor alleged that:
      • Petitioner was not a Filipino citizen, thus not qualified by law to own and operate vessels under Philippine registry.
      • Petitioner violated the contract of sale due to misrepresentation regarding his father’s citizenship.
  • Pertinent Background on Citizenship Claim
    • William Chiongbian’s father, Victoriano Chiongbian:
      • Chinese citizen originally.
      • Elected municipal councilor of Plaridel, Occidental Misamis in 1925.
    • At the time of the 1935 Constitution’s adoption, petitioner William Chiongbian was still a minor.
    • Petitioner claimed Filipino citizenship by virtue of his father’s status.

Issues:

  • Whether William Chiongbian is a Filipino citizen under the 1935 Constitution.
  • Whether the Philippine Shipping Administration validly rescinded the sale of the vessels on grounds of alleged misrepresentation by petitioner.
  • Whether petitioner is qualified by law to own and operate vessels of Philippine registry.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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