G.R. No. 46326 - Hodges vs. Regalado y Maria Gay

Petitioner: Republic of the Philippines, represented by the Special Committee on Naturalization (SCN).
Respondents: Winston Brian Chia Lao, Christopher Troy Chia Lao, and Jon Nicholas Chia Lao.
The petitions involve correction of nationality entries in the Certificates of Live Birth of respondents regarding their parents’ nationality.
The cases were consolidated and directly filed before the Supreme Court as Petitions for Review on Certiorari raising pure questions of law.

Lao Kian Ben and Chia Kong Liong, the parents, married in 1962 in Quezon City.
Children: Jon Nicholas (born 1966), Winston Brian (born 1968), Christopher Troy (born 1973).
The original Certificates of Live Birth show the nationality of both parents as “Chinese.”
Lao Kian Ben applied for and was granted Philippine citizenship under Letter of Instructions No. 270 and Presidential Decree No. 923; took oath and received Certificate of Naturalization in 1976.
Chia Kong Liong also acquired Philippine citizenship as wife of a naturalized citizen; took oath and received Certificate of Naturalization in 1979.
The respondents were born and raised in the Philippines, attended Philippine schools, married Filipino citizens, and raised their families in the Philippines.

Filed Petition and Amended Petition for correction of entry on their parents’ nationality from “Chinese” to “Filipino.”
Trial court set hearing, ordered publication of the petition, and required notice to interested parties.
No opposition was filed; evidence was presented by petitioners with active participation by the public prosecutor.
Decision dated January 2, 2013 granted the petition, ordering correction of the nationality entries in their birth certificates.

Filed Petition and Amended Petition to change parents’ nationality from “Chinese” to “Filipino.”
Court set hearing and ordered publication of notice and service of petition to interested parties.
Jurisdictional requirements under Rule 108 proven; evidence presented.
Decision dated March 13, 2013 granted the petition ordering the corresponding correction.

Republic filed Petitions for Review on Certiorari contesting both RTC decisions.
The issues concern whether correcting nationality entries of respondents’ parents from “Chinese” to “Filipino” is proper without a proceeding before the Special Committee on Naturalization to determine respondents’ own citizenship qualifications.

Whether the nationality of the parents of Winston Brian, Christopher Troy, and Jon Nicholas Chia Lao originally recorded as “Chinese” in their respective Certificates of Live Birth may be changed to “Filipino” considering the parents’ subsequent naturalization.

Whether an appropriate proceeding before the Special Committee on Naturalization, to determine if respondents are qualified to acquire Filipino citizenship, is required before effecting the change of the nationality entry of their parents in their birth certificates.