G.R. No. 132244 . September 14, 1999.
GERARDO ANGAT, petitioner, vs. REPUBLIC OF THE PHILIPPINES, respondent.

FACTS

Petitioner Gerardo Angat, a natural-born Filipino citizen who lost his citizenship by naturalization in the United States, filed a petition on March 11, 1996, before the Regional Trial Court (RTC) of Marikina City to reacquire his Philippine citizenship under Commonwealth Act No. 63 , as amended, and Republic Acts Nos. 965 and 2630. The RTC, in an order dated September 20, 1996, granted petitioner’s motion to take his oath of allegiance under Republic Act No. 8171 . Petitioner took his oath on October 3, 1996, and the court issued an order on October 4, 1996, declaring him repatriated and a citizen of the Philippines. Subsequently, on March 19, 1997, the Office of the Solicitor General (OSG) filed a Manifestation and Motion, asserting that the RTC lacked jurisdiction over the petition. The OSG argued that under Administrative Order No. 285, issued by President Fidel V. Ramos on August 22, 1996, the Special Committee on Naturalization was the proper forum for petitions under R.A. No. 8171 . The RTC, in an order dated September 22, 1997, granted the OSG’s motion and dismissed the petition for lack of jurisdiction, setting aside its previous orders. Petitioner’s motion for reconsideration was denied in an order dated December 29, 1997. Petitioner appealed, contending that the RTC erred in dismissing the petition by giving retroactive effect to Administrative Order No. 285.

ISSUE

Whether the Regional Trial Court had jurisdiction over petitioner’s petition for repatriation filed prior to the effectivity of Administrative Order No. 285, which vested jurisdiction over such petitions in the Special Committee on Naturalization.

RULING

The Supreme Court denied the petition and affirmed the orders of the Regional Trial Court. The Court held that the RTC correctly dismissed the petition for lack of jurisdiction. Administrative Order No. 285, which took effect on August 22, 1996, explicitly vested jurisdiction over petitions for repatriation under R.A. No. 8171 in the Special Committee on Naturalization. The Court ruled that jurisdiction is conferred by law, and at the time the OSG filed its motion to dismiss on March 19, 1997, the law (A.O. No. 285) had already vested exclusive jurisdiction in the Special Committee. The Court further held that the RTC’s earlier orders (September 20, 1996, and October 4, 1996) were null and void for having been issued without jurisdiction. The fact that petitioner filed his petition before the effectivity of A.O. No. 285 did not preclude the application of the new rule, as jurisdiction is determined by the law in force at the time of the commencement of the action, but a subsequent law divesting the court of jurisdiction must be given effect. The Court also noted that R.A. No. 8171 , the law on repatriation, did not specify any particular forum or procedure, thus allowing the President, through an administrative order, to designate the implementing agency. Therefore, the RTC correctly dismissed the petition without prejudice to its refiling before the Special Committee on Naturalization.