Title
Queto vs. Catolico
Case
G.R. No. L-25204
Decision Date
Jan 23, 1970
Judge Catolico nullified naturalization certificates without proper motion, violating due process; Supreme Court ruled his actions lacked jurisdiction and proper procedure.

Case Digest (G.R. No. L-25204)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case involves petitioners who were naturalized citizens whose naturalization certificates were issued between August 27, 1961, and June 6, 1964.
    • Initially, over fifty naturalized citizens were affected by the actions of respondent Judge Alfredo Catolico in Misamis Occidental.
    • Thirty-seven of these citizens filed a petition for prohibition on October 26, 1965, seeking to stop further actions by the judge.
  • Notice and Summoning by the Judge
    • On October 5, 1965, each affected petitioner received a uniformly worded, mimeographed notice from the clerk of the Court of First Instance under Judge Catolico’s supervision.
      • The notice stated that, according to the judge’s instructions and the records, the naturalization proceedings were “null and void” based on recent Supreme Court decisions.
      • It ordered the petitioners to appear on October 15, 1965, at 9:00 a.m. at Oroquieta, Misamis Occidental, to discuss measures to prevent abuses associated with their Philippine citizenship.
    • In the hearing held on October 15, 1965, the judge explained that his action was in response to a letter (from Chua Tuan alias Tian Yu) seeking copies of his naturalization certificate and oath of allegiance for Bureau of Lands requirements.
  • The Judge’s Discourse and Prejudgment
    • During the hearing, Judge Catolico delivered an extensive monologue criticizing provincial and city fiscals in naturalization cases.
      • He vented personal animosity against Chua Tuan, describing him in derogatory and abusive terms (e.g., “balasubas,” “ingrate,” “humbug,” “animalistic,” and a “danger and a disgrace to the community”).
      • The judge asserted that, due to the inherent nullity of the naturalization procedures (not receiving proper notification to the Solicitor General), the petitioners had never acquired valid Filipino citizenship.
    • The judge’s pronouncements extended to all petitioners by implication, though he signaled the willingness to listen to their arguments.
    • The judge later granted a continuance (at counsel’s request to await advice from the Solicitor General) and set a new hearing on November 12, 1965.
  • Subsequent Developments
    • Following the judge’s actions, 35 out of the 37 petitioners withdrew, opting instead to file proper petitions in the lower court to clear their status.
    • Only two petitioners, Chua Tuan (also known as Lim Tian Su) and Pepito Go, remained in the case.
    • The Solicitor General moved to intervene on December 8, 1965; his motion was granted on December 15, 1965.
    • The case was scheduled for another hearing on April 18, 1966, where oral arguments were substituted by memorandum submissions from the petitioners, while the Solicitor General did not submit any memorandum.

Issues:

  • Jurisdictional Question
    • Whether the respondent Judge, acting motu proprio, had the jurisdiction to review and declare null and void the naturalization proceedings.
    • Whether the judge’s unilateral inquiry into the alleged infirmities of the naturalization process was proper, given that proper procedure requires a motion by the Solicitor General or the provincial fiscal.
  • Procedural Due Process
    • Whether the judge’s action of summoning the petitioners and subjecting them to a public and prejudicial inquiry without giving them the full opportunity to be heard violated the fundamental tenets of due process.
  • Separation of Powers and Judicial Authority
    • Whether a judge’s act of taking judicial notice and initiating independent inquiry into the veracity of the naturalization procedures intrudes upon powers that should be exercised by other officials, namely the Solicitor General or fiscal offices.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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