Title
Co vs. Government of the Philippine Islands
Case
G.R. No. 28375
Decision Date
Dec 29, 1928
Basilio Santos Co sought Philippine citizenship, claiming birth in Malolos to a Filipino mother. Insufficient evidence of origin led to denial; burden of proof unmet, naturalization under Act No. 2927 inapplicable.
A

Case Summary (G.R. No. 127246)

Petitioner’s Claims

Basilio Santos Co claims that he is a Filipino citizen by birth, having been born to a Filipino mother, Venancia Santos, in June 1890 in the municipality of Malolos, Province of Bulacan. The applicant asserts that he did not acquire Chinese citizenship during several trips to China, which he undertook for medical treatment and familial reasons throughout his early life.

Evidence Presented

To substantiate his claims, Santos Co introduced Exhibits A and H, which include a baptismal certificate. The certificate indicates that Basilio was baptized on June 4, 1890, in the parish of Malolos and is recorded as being born on June 10, 1890. His mother, Venancia Santos, is identified as a Filipino citizen, which supports his assertion of being a Philippine national. Santos Co testified that his mother confirmed his birthplace and citizenship during his childhood.

Lower Court Findings

The lower court, upon reviewing the evidence, determined that the applicant failed to satisfactorily prove his claim of being born in the Philippines and, consequently, his assertion of Philippine origin. Due to this finding, the court denied the application for citizenship and imposed costs on the applicant.

Legal Framework of Naturalization

Santos Co contended that he is a Philippine citizen by virtue of his birth in the Philippines during Spanish sovereignty, making him a national irrespective of his father's nationality, who was either unknown or a Chinese individual not lawfully married to his mother. Thus, he argued that the naturalization proceedings under Act No. 2927, w

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