Case Digest (G.R. No. L-22041) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Melecio Clarinio Ujano, the petitioner and appellant, sought to reacquire his Philippine citizenship through a petition filed before the Court of First Instance of Ilocos Sur. Ujano was born 66 years prior in Magsingal, Ilocos Sur, to Filipino parents. He was married to Maxima O. Ujano and had one son, Prospero, who had reached the age of majority. In 1927, Ujano relocated to the United States of America, where he lived for over 20 years and eventually acquired American citizenship by naturalization. He returned to the Philippines on November 10, 1960, but was admitted only for a temporary stay. At the time of his application, he owned agricultural land and a residential property in Magsingal, valued at no less than P5,000.00, and received a monthly pension of $115.00 from the Social Security Administration in the United States. He had no criminal record and intended to renounce his allegiance to the United States. However, the court a quo denied his petition, citing that he did Case Digest (G.R. No. L-22041) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Petitioner
- Petitioner: Melecio Clarinio Ujano, a natural-born Filipino, born in Magsingal, Ilocos Sur, to Filipino parents.
- Personal details: He is 66 years old, married to Maxima O. Ujano, and has one son, Prospero, who is of legal age.
- Historical and Citizenship Details
- In 1927, the petitioner left the Philippines for the United States of America.
- After residing in the U.S. for over 20 years, he acquired American citizenship through naturalization.
- Petition for Reacquisition of Philippine Citizenship
- The petitioner filed a petition before the Court of First Instance of Ilocos Sur seeking to reacquire his Philippine citizenship.
- Included in his petition were details showing that he possesses property in the Philippines—a residential house and agricultural land in Magsingal, Ilocos Sur—with a value not less than ₱5,000.00.
- He also receives a monthly pension of $115.00 from the United States Social Security Administration.
- It is noted that he has no record of conviction and has expressed his intention to renounce his allegiance to the U.S.A.
- Circumstances of Stay in the Philippines
- The petitioner returned to the Philippines on November 10, 1960, but his entry was on a temporary basis.
- At the time of filing his petition for reacquisition of citizenship, his status remained that of a temporary visitor.
- Trial Court Proceedings
- The Court of First Instance of Ilocos Sur denied the petition on the ground that the petitioner did not satisfy the statutory requirement of residing in the Philippines for at least six months immediately prior to filing his petition.
- The court emphasized that "residence" implies not merely physical presence but a permanent domicile, characterized by the intent to remain in a fixed place.
Issues:
- Legal Interpretation of "Residence"
- Whether the petitioner's temporary visitor status could be equated with "residence" under Section 3(1) of Commonwealth Act No. 63.
- Whether the period of temporary stay fulfilled the requirement of having an established domicile and permanent home in the Philippines.
- Compliance with Reacquisition Requirements
- Whether the petitioner met the mandatory six-month residency requirement prior to filing his petition for reacquisition of Philippine citizenship.
- The broader issue of whether temporary admission, despite actual physical presence, qualifies as establishing residence for citizenship purposes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)