G.R. No. L-32010. March 29, 1971.
REPUBLIC OF THE PHILIPPINES, petitioner, vs. HON. ANGEL P. BACANI, as Judge of the Court of First Instance of Pangasinan, Branch IX, and YU LAN, alias DY KIAMA, respondents.

FACTS

The Republic filed a special civil action for certiorari and prohibition to annul an order dated March 10, 1970, issued by respondent Judge Angel P. Bacani in Special Proceeding No. U-316. The order pertained to a proceeding where the private respondent, Yu Lan alias Dy Kiama, was declared a Filipino citizen. The petitioner sought to restrain the implementation of this order and to enjoin Yu Lan from representing himself as a citizen or exercising related rights. The petition alleged that the respondent judge acted without or in excess of jurisdiction or with grave abuse of discretion. This Court initially issued a writ of preliminary injunction on July 1, 1970.
In his answer, Yu Lan asserted affirmative defenses, arguing that Courts of First Instance, as courts of general jurisdiction, possess the competence to interpret constitutional provisions and decide questions of citizenship arising under the Treaty of Paris or the Philippine Bill of 1902, whether such questions are the main issue or merely incidental to a proceeding. He contended that the absence of a specific statutory proceeding for declaring citizenship does not preclude courts from making such determinations.

ISSUE

Whether a Court of First Instance has jurisdiction to declare an individual a Filipino citizen in a special proceeding instituted solely for that purpose.

RULING

The Supreme Court granted the motion filed by the private respondent, with the conformity of the Solicitor General, to set aside the lower court’s decision. The ruling implicitly affirms the Republic’s position on jurisdictional grounds. The legal logic is grounded in the principle that jurisdiction is conferred only by law. While Courts of First Instance are courts of general jurisdiction, their authority is not plenary and must be anchored in a specific grant of power by statute or the Constitution.
No law vests original jurisdiction in Courts of First Instance to conduct special proceedings for the sole purpose of declaring an individual’s citizenship. Questions of citizenship may be resolved incidentally in proceedings where citizenship is a prerequisite for granting a substantive right (e.g., in land registration or election cases), but a direct action for a declaratory judgment of citizenship is not a justiciable controversy recognized under existing procedural rules. The lower court, therefore, acted without jurisdiction in issuing a declaratory order on citizenship in a special proceeding initiated for that exclusive aim. Consequently, the decision was declared null and void and of no legal effect.