G.R. No. L-37223. March 25, 1982.
IN THE MATTER OF THE PETITION OF CHUA SIONG TEE alias CHUA SIONG BEE alias VICENTE CHUA TO BE ADMITTED A CITIZEN OF THE PHILIPPINES, CHUA SIONG TEE, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

The Republic of the Philippines appealed the decision of the Court of First Instance of Cebu dated March 8, 1972, which granted the petition for naturalization of appellee Chua Siong Tee (also known as Chua Siong Bee or Vicente Chua). The State opposed the grant, alleging that the petitioner’s witnesses were incompetent and that he had not conducted himself in a proper and irreproachable manner during his entire period of residence in the Philippines. The case was duly submitted for decision before the Supreme Court after the parties filed their respective briefs.
Subsequently, on January 21, 1982, the Office of the Solicitor General filed a Manifestation and Motion. It informed the Court that during the pendency of this appeal, Chua Siong Tee had filed a separate application for naturalization under Letter of Instructions No. 270. Upon the recommendation of the Special Committee on Naturalization, he was granted Philippine citizenship on November 26, 1976, pursuant to Presidential Decree No. 1055. The pleading included copies of his Oath of Allegiance and Certificate of Naturalization as annexes.

ISSUE

Whether the appeal filed by the Republic of the Philippines has been rendered moot and academic by the subsequent grant of Philippine citizenship to the appellee under a different administrative proceeding.

RULING

Yes, the appeal is dismissed for being moot and academic. The core legal principle applied is that a case becomes moot when there is no longer any justiciable controversy or when the issues presented have been overtaken by supervening events, rendering a judicial resolution unnecessary and without practical legal effect. Here, the appellee had already been conferred Philippine citizenship through a subsequent administrative naturalization process under Presidential Decree No. 1055, which was effective and valid. This grant of citizenship during the appeal’s pendency achieved the very objective of the original judicial naturalization petition. Therefore, any ruling on the merits of the lower court’s decision regarding witness competency or the petitioner’s conduct would be an exercise in futility, as the appellee is already a naturalized citizen. The Supreme Court, recognizing this supervening event, dismissed the case. No costs were awarded.