GR L 37074; (May, 1982) (Digest)

G.R. No. L-37074. May 31, 1982.
IN THE MATTER OF THE PETITION OF BENITO LEE TO BE ADMITTED A CITIZEN OF THE PHILIPPINES, BENITO LEE, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Benito Lee filed a petition for naturalization under Commonwealth Act No. 473, also known as the Revised Naturalization Law. The Court of First Instance of Manila granted his petition in a decision dated September 25, 1972. The Republic of the Philippines, as oppositor, appealed this grant to the Supreme Court, arguing against Lee’s qualification for citizenship. During the pendency of this appeal, the legal landscape for naturalization changed significantly with the issuance of Letter of Instructions No. 270 and Presidential Decree No. 923, which established a new administrative naturalization process.
While his judicial naturalization case was under review by the Supreme Court, Benito Lee availed himself of this new administrative procedure. He filed an application under the said laws, and upon recommendation of the Special Committee on Naturalization, he was granted Philippine citizenship on April 20, 1976. The Office of the Solicitor General, representing the Republic, subsequently filed an Ex-Parte Manifestation and Motion before the Supreme Court, attaching copies of Lee’s Oath of Allegiance and Certificate of Naturalization as proof.

ISSUE

Whether the appeal from the lower court’s decision granting Benito Lee’s petition for naturalization has been rendered moot and academic by his subsequent acquisition of Philippine citizenship through a separate administrative process.

RULING

Yes, the appeal is moot and academic. The Supreme Court dismissed the case. The core legal logic is that a court will not determine a case where there is no longer an actual controversy or where the issues have become academic. The grant of judicial relief requires a live dispute. Here, the very objective of the original petition—to have Benito Lee admitted as a Philippine citizen—had already been fully achieved through an independent and valid administrative proceeding. He had already taken his Oath of Allegiance and received a Certificate of Naturalization under Presidential Decree No. 923.
This subsequent grant of citizenship rendered the appeal from the earlier judicial decision devoid of practical legal effect. A decision from the Supreme Court on the merits of the lower court’s ruling, whether affirming or reversing it, would be inoperative and could not alter Lee’s current status as a naturalized citizen conferred by the executive branch under a subsequent law. The Court therefore applied the well-settled doctrine of mootness, which dictates that it will not engage in adjudication where its judgment can no longer provide any tangible remedy or affect the rights of the parties. No costs were awarded.