G.R. No. 262938 , December 5, 2023
Walter Manuel F. Prescott, Petitioner, vs. Bureau of Immigration and the Department of Justice, Respondents.

FACTS

Petitioner Walter Manuel F. Prescott was born in 1950 in the Philippines to an American father and a Filipino mother. He was issued an Alien Certificate of Registration in 1951. In 1977, the American Embassy informed him he had lost his U.S. citizenship. In 2006, he became a naturalized American citizen. In 2008, he applied for and was granted reacquisition of Philippine citizenship under Republic Act No. 9225 (Citizenship Retention and Re-acquisition Act), taking an oath of allegiance and receiving an Identification Certificate and a Philippine passport. In 2012, his estranged wife filed a complaint with the Bureau of Immigration (BI), alleging he illegally reacquired citizenship. The BI and the Department of Justice (DOJ) subsequently ruled he was ineligible for RA 9225, canceled his certificate, and initiated deportation proceedings. Prescott argued he was denied due process as he was never properly notified of the hearings leading to the cancellation.

ISSUE

The core issue is whether the BI and the DOJ violated Prescott’s right to due process in the proceedings that led to the cancellation of his certificate of reacquired Philippine citizenship and the issuance of the deportation charge.

RULING

Yes, the BI and DOJ violated Prescott’s constitutional right to due process. The Court emphasized that administrative proceedings, including deportation cases, must comply with the fundamental requirements of due process: the right to a hearing and the opportunity to present one’s case. The records showed that notices for the 2012 BI hearings were sent to an address in Tagaytay City but were returned “unserved” or indicated Prescott was “out of the country.” Crucially, the BI and DOJ failed to present proof that this was Prescott’s correct or last known address at that time. There was no evidence they attempted other reasonable means to serve him. Consequently, the proceedings that resulted in the cancellation of his citizenship reacquisition were void for lack of proper notice and hearing. The subsequent deportation charge, which was premised on this invalid cancellation, was likewise void. The Court stressed that the right to be heard is indispensable, and the State cannot deprive an individual of a secured status, such as citizenship, through proceedings that disregard this basic guarantee. The grant of the petition rendered the ancillary issue on Prescott’s citizenship moot. The Court set aside the challenged CA decision and resolutions and the BI and DOJ orders, permanently enjoining the deportation proceedings.