Case Digest (G.R. No. 262938) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
Walter Manuel F. Prescott (Prescott), born April 10, 1950 in the Philippines to an American father and a Filipino mother, was issued an Alien Certificate of Registration by the Bureau of Immigration (BI) on January 12, 1951. Unaware of any other citizenship, he lived, studied, married a U.S. citizen in 1981, and had three children. In 1977, the U.S. Embassy notified him he lost American citizenship in 1976 for overstaying. He naturalized as a U.S. citizen in 2006 and traveled on a “balikbayan” status. On November 26, 2008, he applied for and obtained dual Philippine citizenship under Republic Act No. 9225, took his Oath of Allegiance, and received a Philippine passport. In 2012, his wife and an associate filed a complaint with the BI alleging he fraudulently reacquired Philippine citizenship. Notices for hearings went unserved. The BI conducted no proper hearing but on October 17, 2013 declared him an American citizen, and the Department of Justice (DOJ) cancelled his Certificat Case Digest (G.R. No. 262938) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Personal and early citizenship history
- Walter Manuel F. Prescott was born on April 10, 1950 in the Philippines to an American father and a Filipino mother; issued an Alien Certificate of Registration (ACR) on January 12, 1951 and lived in the Philippines.
- In 1976, he lost U.S. citizenship for overstaying; married a U.S. citizen in 1981; first child born in Philippines (1981), two more in the U.S. (1986, 1988).
- U.S. naturalization and Philippine dual-citizenship application
- Became a naturalized American on August 5, 2006; traveled to the Philippines thereafter as a “balikbayan.”
- On November 26, 2008, applied under RA 9225 for dual citizenship; took Oath of Allegiance; received Identification Certificate and Philippine passport in September 2009.
- BI-DOJ complaint, revocation, and deportation order
- June 6, 2012: ex-wife and third party filed complaint alleging fraudulent reacquisition; BI notices for hearings (July–September 2012) were returned unserved.
- October 17, 2013: BI resolved that Prescott remained an alien; November 28, 2013 DOJ Secretary approved revocation of his dual-citizenship order.
- March 29, 2016: BI issued deportation order (D.C. No. SBM/LD-15-08/07-659); August 22, 2016 warrant executed; Prescott arrested August 25, 2016 and detained at Camp Bagong Diwa.
- Lower court proceedings
- March 2019: Prescott filed RTC Manila Branch 10 petitions for (a) declaratory relief to declare his Philippine citizenship; and (b) habeas corpus for unlawful detention.
- March 21, 2019 RTC denied habeas corpus; May 24, 2019 RTC denied declaratory relief but ordered BI and DOJ to deport within 30 days or release him.
- June 25, 2021: CA denied Prescott’s appeal and ordered immediate turnover to BI/DOJ for deportation; August 15, 2022: CA denied his motion for reconsideration.
- Supreme Court petition and briefing
- Prescott filed a Petition for Review on Certiorari under Rule 45; OSG filed Comments; hearing held March 13, 2023; memoranda submitted by both parties.
Issues:
- Whether the BI complaint was a collateral or direct attack on Prescott’s citizenship.
- Whether BI proceedings and the DOJ November 28, 2013 Resolution revoking his dual-citizenship order violated due process and are void.
- Whether declaratory relief and habeas corpus were proper remedies in his circumstances.
- Whether Prescott, born in 1950 to an American father and Filipino mother under the 1935 Constitution, is a natural-born Filipino and eligible under RA 9225.
- Whether Prescott must be released from detention.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)