G.R. No. L-14653. January 31, 1963.
IN THE MATTER OF THE PETITION FOR CANCELLATION OF ALIEN CERTIFICATE OF REGISTRATION. RICARDO SANTIAGO, petitioner-appellee, vs. COMMISSIONER OF IMMIGRATION, respondent-appellant.

FACTS

Ricardo Santiago filed a petition in the Court of First Instance of Negros Occidental, initially praying to be declared a Philippine citizen and for the cancellation of his Alien Certificate of Registration (ACR), which he claimed was erroneously issued. He presented evidence that he was born in 1904 in La Carlota, Negros Occidental, to a Filipina mother and a Chinese father. He argued that despite being a Filipino citizen, his father had erroneously registered him as an alien before dying in 1928, and this registration was periodically renewed, with the latest ACR issued in 1950.
The lower court initially granted Santiago’s petition, declaring him a Filipino citizen and ordering the cancellation of his ACR. However, upon the Solicitor General’s motion for reconsideration, the court set aside its order, agreeing that an action for declaratory relief was not the proper remedy. Santiago then moved for reconsideration, amending his prayer to eliminate the express declaration of citizenship, seeking only the cancellation of his ACR. The court subsequently reinstated its original order but modified it by removing the explicit declaration of citizenship, ordering only the cancellation of the ACR.

ISSUE

Whether the lower court properly took cognizance of Santiago’s petition, which sought the cancellation of his Alien Certificate of Registration based on his claim of Philippine citizenship.

RULING

The Supreme Court reversed the lower court’s order and dismissed the petition. The Court held that the proceeding, whether construed directly or indirectly, was essentially one seeking a judicial declaration of Santiago’s Philippine citizenship. The Court ruled that no proceeding, whether for declaratory relief or otherwise, is available under Philippine law for the express purpose of obtaining a judicial declaration of citizenship. Declaratory relief is a special civil action available only for the construction of deeds, wills, contracts, statutes, or ordinances to determine rights thereunder, and citizenship status does not fall under any of these categories.
The Court distinguished the cases cited by Santiago and the lower court (U.S. vs. Ong Tian Se, Santos Co vs. P.P.I., and Luis Serra vs. Republic). Those cases involved deportation proceedings where citizenship was raised as a defense, or naturalization petitions where evidence showed the applicants were already Filipinos, making naturalization unnecessary. The nature of those proceedings was fundamentally different from Santiago’s direct petition. Since the remedy sought was improper, the Supreme Court deemed it unnecessary to rule on the sufficiency of the evidence presented to prove Santiago’s citizenship. The order for cancellation of the ACR, which was predicated on an implicit declaration of citizenship, was therefore invalid.