GR L 21664; (March, 1969) (Digest)
G.R. No. L-21664 and L-21665, March 28, 1969.
Republic of the Philippines and The Commissioner of Immigration, petitioners, vs. Hon. Manolo L. Maddela, as Judge of the Court of First Instance of Quezon, Branch II, and Miguela Tan Suat, respondents. (L-21664)
Republic of the Philippines and The Commissioner of Immigration, petitioners, vs. Hon. Manolo L. Maddela, as Judge of the Court of First Instance of Quezon, Branch II and Chan Po Lan, respondents. (L-21665)
FACTS
Two separate petitions for certiorari and prohibition were consolidated. The Court of First Instance of Quezon, presided by Judge Manolo L. Maddela, rendered two decisions in Special Proceeding Nos. 4012 and 4013 on April 29, 1963. In Special Proceeding No. 4012, the court declared Miguela Tan Suat, a Chinese national, a Filipino citizen by virtue of her marriage to Sy Ing Seng, a Filipino citizen, in 1937. In Special Proceeding No. 4013, the court similarly declared Chan Po Lan, a Chinese national, a Filipino citizen by virtue of her marriage to Cu Bon Piao, a Filipino citizen, in 1961. In both cases, the court ordered the Commissioner of Immigration to cancel the respondents’ alien certificates and issue identification cards. The Solicitor General, who was not furnished copies of the petitions nor authorized the Provincial Fiscal’s appearance, filed notices of appeal. Due to delays in receiving the records, the Solicitor General filed the instant petitions, including the Commissioner of Immigration as a co-petitioner. This Court issued preliminary injunctions to restrain the judgments’ enforcement.
ISSUE
Whether the Court of First Instance had jurisdiction to render a judicial declaration of citizenship in favor of the private respondents.
RULING
The writs of certiorari and prohibition are granted. The questioned decisions are set aside, and the preliminary injunctions are made permanent. The Supreme Court ruled that under Philippine laws, there is no action or proceeding for the judicial declaration of an individual’s citizenship. Courts exist to settle justiciable controversies involving a legally demandable right, an act violative of that right, and a legal remedy. A pronouncement on citizenship status may only be made as an incident to adjudicating the rights of parties in a controversy. There is no legislation authorizing a judicial proceeding solely to declare that a person is a citizen. The lower court, therefore, acted without jurisdiction in granting the petitions for declaration of citizenship.