G.R. No. 30685 , July 29, 1929
RATAN SINGH, plaintiff-appellant, vs. THE GOVERNMENT OF THE PHILIPPINE ISLANDS, opponent-appellee.

FACTS

Ratan Singh, a British subject born in Sangtipur, Jullunder, Punjab, India, filed an application for naturalization as a citizen of the Philippine Islands under Act No. 2927. He alleged he possessed all qualifications and none of the disqualifications under the law. His parents were natives of Kohek, Province of Baluchistan, India. The Government opposed the application. The Court of First Instance of Zambales, after hearing, denied the application, ruling that the petitioner was not qualified under Section 1(c) of Act No. 2927 in relation to Section 3 of the U.S. Act of Congress of February 5, 1917. Ratan Singh appealed.

ISSUE

Whether Ratan Singh, a native of Punjab, India (and claiming native origin through his parents from Baluchistan, India), is a “foreigner who under the laws of the United States may become a citizen” of the United States if residing therein, and thus qualified for naturalization under Philippine law (Act No. 2927, Section 1(c)).

RULING

No. The Supreme Court affirmed the denial of the application. The Court held that Ratan Singh was not qualified for naturalization.

1. Application of U.S. Immigration Law: Under Section 1(c) of Act No. 2927, eligibility for Philippine citizenship extended to foreigners who could become U.S. citizens under U.S. law if residing there. The applicable U.S. law was the Act of Congress of February 5, 1917, which applied to the Philippines. Section 3 of this Act excluded from admission into the United States natives of a broadly defined Asiatic zone, which included India. A specific exception was made for natives of a smaller territory within Asia defined by specific longitude and latitude coordinates.

2. Petitioner’s Failure of Proof: Ratan Singh’s claim that his parents’ native place, Kohek in Baluchistan, fell within the excepted territory was not substantiated by any evidence. The Court, consulting reference maps, found that the Province of Baluchistan lay within the excluded Asiatic zone and outside the excepted territory, and no place named “Kohek” was located within the excepted area.

3. Principle of Jus Soli and U.S. Precedent: As a British subject, the principle of jus soli (right of soil) applied to determine his nationality. He was therefore legally a native of Punjab, India, where he was born. The U.S. Supreme Court, in United States vs. Bhagat Singh Thind, had already ruled that a native of Punjab, India, was not eligible for naturalization as a U.S. citizen. This precedent was binding.

Since Ratan Singh, as a native of India within the excluded zone, could not become a citizen of the United States under its laws, he consequently did not belong to the class of foreigners eligible for Philippine citizenship under Act No. 2927. The judgment of the lower court was affirmed.