G.R. No. 47616 - Tan Chong vs. Secretary of Labor

Tan Chong vs. Secretary of Labor

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Title Supreme Court: Tan Chong vs. Secretary of Labor

Case: G.R. No. 47616

Decision Date: Sep 16, 1947

Jose Tan Chong and Lam Swee Sang, born in the Philippines to Chinese fathers and Filipino mothers, sought recognition as Filipino citizens. The Supreme Court reversed prior rulings, rejecting jus soli and holding that citizenship under the Philippine Bill (1902) required parents to be Spanish subjects. Tan Chong was denied citizenship, while Lam Swee Sang’s naturalization was upheld. The Court emphasized birthright limitations and discouraged dual allegiance.

citizenship

jus soli

association

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