G.R. No. L-34030 - Commissioner of Immigration vs. Vamenta, Jr.

Felisa Lee, also known as Lee Siu Luan, is a Chinese citizen born on March 1, 1938, in Manila.
On June 22, 1958, she married Jackson Barra, a Filipino citizen by birth.
Believing that her marriage to a Filipino endowed her with the qualifications for naturalization as provided by law, she claimed to have acquired Filipino citizenship through her husband.

Initially, Felisa Lee applied to the Commissioner of Immigration for the cancellation of her Alien Certificate of Registration on the ground that she had, by virtue of marriage, acquired Filipino citizenship.
In a letter dated October 4, 1962, the Commissioner responded that due to an existing policy, wives of Filipino citizens must seek judicial determination on their qualifications and disqualifications for naturalization.
Consequently, on October 13, 1962, Felisa filed a petition before the Court of First Instance of Albay to have her alien registration cancelled and to be declared a Filipino citizen.

The petition alleged that she possessed all the necessary qualifications and none of the disqualifications for naturalization under Section 15 of Commonwealth Act No. 473.
Felisa contended that because of her marriage, she should automatically be deemed a Filipino citizen.
On November 2, 1962, the Solicitor General moved to dismiss the petition on the ground that the court lacked jurisdiction over an act committed outside its judicial district, framing the petition as one for mandamus.
The petitioner rebutted that her petition was not for mandamus but for a judicial determination of her naturalization status under the applicable law.

On November 20, 1962, the Court of First Instance denied the motion to dismiss.
After proper proceedings, the trial court ruled in favor of Felisa Lee, declaring that she met all qualifications and was not disqualified from becoming a Filipino citizen by virtue of her marriage.
The court ordered the Commissioner of Immigration to cancel her Alien Certificate of Registration once the decision became final.

The Commissioner of Immigration appealed the trial court’s decision.
The central contention on appeal was that the petitioner’s action was essentially one for declaratory relief concerning citizenship—a procedure not provided for by law.

Whether the petition should be characterized as one for mandamus or as an ordinary action for declaratory relief.
Whether the petition seeking judicial declaration of citizenship is a proper remedy under existing statutes and rules.

Whether the Court of First Instance had jurisdiction to render a decision on an act that involves performing an official function outside its judicial district.
The propriety of ordering the cancellation of the petitioner’s Alien Certificate of Registration solely based on a judicial determination of her citizenship.

Whether there exists a judicial process for the declaration of citizenship for an alien woman who marries a Filipino citizen.
How the absence of an established legal procedure for such a declaration affects the petitioner’s claim to Filipino citizenship by marriage.