G.R. No. L-41599. October 19, 1976.
IN THE MATTER OF THE PETITION OF WILLIAM CHAN TO BE ADMITTED AS CITIZEN OF THE PHILIPPINES, WILLIAM CHAN, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

On September 9, 1971, petitioner William Chan filed a petition for naturalization with the Court of First Instance of Negros Occidental, docketed as Nat. Case No. 10005. The lower court rendered a decision on September 30, 1974, admitting Chan to Philippine citizenship. The Republic of the Philippines, through the Solicitor General, appealed this decision to the Supreme Court on April 22, 1975.
Subsequently, on September 29, 1976, the Acting Solicitor General filed a “Manifestation Withdrawing Appeal and Motion to Dismiss the Case” with the Supreme Court. The manifestation alleged that petitioner-appellee William Chan had already been duly naturalized as a citizen of the Philippines under Presidential Decree No. 923. He was issued Naturalization Certificate No. 004750 dated May 19, 1976. Based on this supervening event, the Republic prayed for the dismissal of the case for having become moot and academic.

ISSUE

Whether the appeal should be dismissed on the ground of mootness due to the petitioner’s subsequent naturalization under Presidential Decree No. 923.

RULING

Yes, the appeal is dismissed for being moot and academic. The Supreme Court granted the motion to dismiss filed by the Acting Solicitor General. The legal logic is anchored on the doctrine of mootness, which dictates that courts will not determine cases where no actual controversy exists or where the issues have ceased to be justiciable due to subsequent events.
The core subject of the appeal was the propriety of the lower court’s decision granting Chan’s petition for naturalization under the judicial process. However, during the pendency of the appeal, a supervening event rendered a resolution on the merits unnecessary. Chan had already been conferred Philippine citizenship through an executive mechanism, specifically under Presidential Decree No. 923, and was issued a corresponding naturalization certificate. This grant of citizenship was an accomplished fact that removed any live dispute between the parties. Deciding whether the lower court correctly granted the judicial naturalization petition would be an exercise in futility, as the petitioner had already attained the status he sought through an alternative, valid legal avenue.
The Court, citing precedents such as Yu Hio Soo v. Republic, applied the principle that it will not engage in adjudication when its judgment can no longer provide any practical legal effect or relief. The appeal was therefore dismissed for being moot and academic, with no pronouncement as to costs.