Case Summary (G.R. No. L-2007)
Applicable Law and Constitutional Provisions
The case is governed by Article IV of the 1935 Philippine Constitution, which details the acquisition and loss of Philippine citizenship. Specifically:
- Section 1 enumerates the classes of Filipino citizens, including those who were citizens at the time of the Constitution’s adoption, those whose fathers or mothers are citizens, and those naturalized under law.
- Section 2 provides that citizenship may be lost or reacquired as provided by law.
Facts Regarding Citizenship
Victoriano Chiongbian, petitioner William Chiongbian's father, was a Chinese citizen who was elected as municipal councilor of Plaridel, Occidental Misamis, in 1925. This fact is substantiated by ample evidence including findings by the National Bureau of Investigation and accepted pleadings of the respondents. At the time the Constitution was adopted, William Chiongbian was still a minor.
Legal Determination of Citizenship
Under Article IV, Section 1, Subsection 2 of the Constitution, Victoriano Chiongbian, having been elected to public office prior to the adoption of the Constitution, acquired Filipino citizenship by operation of law. As a legitimate minor child, William Chiongbian also acquired Filipino citizenship through his father pursuant to Subsection 3. This is consistent with the settled principle that citizenship of a legitimate minor child follows that of the father.
Respondents’ Arguments and Court’s Rebuttal
Respondents contended that the citizenship accorded by Subsection 2 was strictly personal to Victoriano Chiongbian and did not extend to his descendants. They based their argument on two points: (1) that the subsection was included merely to grant citizenship to a particular delegate of the Constitutional Convention, and (2) that the original draft’s phrase “and their descendants” was deleted, indicating a limited application.
The Court rejected both arguments. It reasoned that the framers intended the provision to have full substance and to work harmoniously with other citizenship provisions, including the transmissive nature of citizenship to descendants under Subsection 3. The deletion of “and their descendants” was considered a non-determinative drafting choice, likely due to redundancy, and did not override the final operative constitutional text.
Allegation of Contract Misrepresentation
Respondents also alleged that petitioner misrepresented his father’s citizenship status in the contract of sale of the vessels, stating that his father was naturalized. The Court held this claim to be without merit, regarding it as a non-deliberate error typical of an individual not skilled in legal nuances. The petitioner intended to convey that his father was a Filipino citizen by operation of law rather than by birth or formal natur
...continue readingCase Syllabus (G.R. No. L-2007)
Background and Nature of the Petition
- The case involves a petition filed by William Chiongbian seeking a writ of prohibition.
- The petition aims to prevent the respondent Customs officials from canceling the registration certificates of vessels owned by the petitioner.
- Additionally, the petitioner seeks to enjoin the Philippine Shipping Administration from rescinding the sale of three vessels previously sold to him.
- The respondents’ principal justification for their actions is the allegation that the petitioner is not a Filipino citizen and is therefore ineligible under Philippine law to own and operate vessels registered in the Philippines.
- The Philippine Shipping Administration also alleges that the petitioner misrepresented facts in the contract of sale, stating that his father was a naturalized Filipino citizen.
- The Philippine Shipowners' Association intervened and filed an answer opposing the petitioner.
Central Issue: Citizenship of William Chiongbian
- The pivotal issue of the case is whether William Chiongbian is a Filipino citizen under the Philippine Constitution.
- The Supreme Court ruled that William Chiongbian is indeed a Filipino citizen.
- Key constitutional provision relied upon is Article IV of the 1935 Philippine Constitution, which defines Filipino citizenship.
- Article IV, Section 1 lists the categories of Filipino citizens, particularly relevant are:
- Subsection 1: Citizens at the time of the adoption of the Constitution.
- Subsection 2: Those born in the Philippines to foreign parents who had been elected to public office before the Constitution's adoption.
- Subsection 3: Those whose fathers are Filipino citizens.
- Section 2 notes that citizenship can be lost or reacquired in the manner provided by law.
Facts Supporting Petitioner’s Citizenship
- Victoriano Chiongbian, William's father, was a Chinese citizen who was elected as municipal councilor in Plaridel, Occidental Misamis in 1925, prior to the 1935 Constitution.
- The election to public office before the adoption of the Constitution fulfills the requirement of Article IV, Section 1, Subsection 2.
- At the time the Constitution was adopted, petitioner William Chiongbian was still a minor.
- Under Article IV, Section 1, Subsection 3, because Victoriano became a