G.R. No. 27240 , February 25, 1928
CLAUDIO LUCIO (alias Tan Cauco), petitioner-appellee, vs. THE GOVERNMENT OF THE PHILIPPINE ISLANDS, respondent-appellant.

FACTS

Claudio Lucio, a 61-year-old Chinese merchant residing in Puerto Princesa, Palawan, filed an application for Philippine citizenship. He arrived in the Philippines in 1881 and had resided continuously since 1914, except for brief visits to China. He met the residency, property, and character requirements under Act No. 2927 (the Philippine Naturalization Law). The Court of First Instance of Palawan granted his petition. The provincial fiscal, on behalf of the Attorney-General, moved for a new trial, arguing the decision was contrary to law. The trial court denied the motion, reasoning that the government had not formally entered its appearance and that its decision had already become final. The government appealed.

ISSUE

Whether a native of China, being of Mongolian race, is eligible for naturalization as a Philippine citizen under Act No. 2927, in light of applicable U.S. laws.

RULING

NO. The Supreme Court reversed the trial court’s decision and denied the petition for citizenship.

The Court held that the petitioner, a Chinese native, did not fall within any of the classes of persons eligible for Philippine citizenship under Section 1 of Act No. 2927. This law, authorized by the U.S. Congress, only allowed naturalization for: (a) natives of the Philippines not already citizens under the Jones Law; (b) natives of other U.S. insular possessions; and (c) foreigners who, under U.S. laws, could become citizens of the United States if residing there.

The petitioner belonged to class (c) “foreigners.” However, U.S. laws at the time explicitly prohibited the naturalization of persons of the Mongolian race, including Chinese. The Court cited Section 14 of the U.S. Act of Congress of May 6, 1882 (the Chinese Exclusion Act), which stated that “no State court or court of the United States shall admit Chinese to citizenship.” Since Act No. 2927 incorporated the eligibility standards of U.S. naturalization law, a Chinese alien was legally disqualified from becoming a Philippine citizen.

The Court also found that the trial court erred in denying the government’s motion for a new trial, as the Attorney-General or the provincial fiscal had the right to appear on behalf of the government in naturalization proceedings under Section 8 of Act No. 2927.