G.R. No. L-39326 June 3, 1976
ANTONIO K. GO, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Antonio K. Go filed a petition for naturalization under the Revised Naturalization Law (Commonwealth Act No. 473) in the Court of First Instance of Tarlac. The trial court denied his petition in a decision dated June 26, 1974. Go subsequently appealed this denial to the Supreme Court. After he had filed his appellant’s brief, the Solicitor General moved to suspend the period for filing the oppositor-appellee’s brief. The motion was grounded on the fact that Go had separately filed an administrative application for naturalization under Letter of Instructions No. 270, a different legal mechanism for acquiring citizenship.
The Supreme Court granted the motion for suspension. Subsequently, the Assistant Solicitor General informed the Court that Go’s administrative application for naturalization (SCN Case No. 000046) had been approved. Go took his oath as a Filipino citizen on January 23, 1976, pursuant to Presidential Decree No. 836, and was issued Certificate of Naturalization No. 001067 dated February 25, 1976.

ISSUE

Whether the appeal from the denial of the judicial petition for naturalization should be resolved on the merits, given that the appellant had already been granted Filipino citizenship through an administrative naturalization process.

RULING

The Supreme Court dismissed the appeal as moot and academic. The core legal logic is that a case becomes moot when there is no longer any justiciable controversy or when the issues presented have been rendered academic by supervening events. The central objective of Go’s appeal was to reverse the lower court’s decision and secure a judicial declaration of his right to Philippine citizenship. However, during the pendency of the appeal, he successfully obtained Philippine citizenship through a separate, valid, and completed administrative process under Letter of Instructions No. 270 and Presidential Decree No. 836. This administrative grant conferred upon him the very status and legal rights he sought through his judicial petition. Consequently, a decision from the Supreme Court on the merits of the denied judicial petition would serve no practical legal purpose. It would neither enhance nor diminish his already vested rights as a naturalized Filipino citizen. The Court therefore refrained from rendering an unnecessary judgment, adhering to the principle that it will not determine questions that no longer exist or affect the parties’ rights. The dismissal was without costs.