Angat vs Republic of the Philippines

G.R. No. 132244, 14 September 1999 [Naturalization; Reacquisition; RA No. 8171]

FACTS:
Gerardo Angat, a natural born Filipino citizen, asked to regain his status as a Philippine citizen before the
RTC Marikina. He was a Filipino citizen until he lost his citizenship by naturalization in US. His first
petition was denied by the trial judge. But then, in his second motion, the court found his petition
meritorious. After a close scrutiny of R.A. 8171, RTC allowed him to take his Oath of Allegiance on
October 3, 1996 and the following day, the RTC declared him as citizen of the Philippines pursuant to
R.A. No. 8171.
OSG filed a Manifestation and Motion in March 1997, asserting that the petition should have been
dismissed by the court for lack of jurisdiction. The motion of OSG was granted. The petitioner filed a
motion for reconsideration questioning the order asseverating that since his petition was filed on
14 March 1996, or months before the Special Committee on Naturalization was constituted by
the President under AO 285 on 22 August 1996, the court a quo had the authority to take
cognizance of the case.
In the Order, dated 29 December 1997, the trial judge denied the motion for reconsideration.
Hence, this petition for certiorari.
ISSUE:
Whether or not the RTC has jurisdiction in deciding over repatriation case.
RULING:
No. A petition for repatriation should be filed with the Special Committee on Naturalization and not with
the RTC which has no jurisdiction. Therefore, the court's order was null and void.
RA No. 8171, which has lapsed into law on October 23 1995, is an act providing for repatriation of
Filipino women who have lost their Philippine citizenship by marriage to aliens and of natural-born
Filipinos who have lost the Philippine citizenship on account of political or economic necessity.
Moreover, petitioner was incorrect when he initially invoked RA 965 and RA 2630, since these laws
could only apply to persons who had lost their Philippine citizenship by rendering service to, or
accepting commission in, the armed forces of an allied country or the armed forces of the US, a factual
matter not alleged in his petition. Parenthetically, under these statutes, the person desiring to reacquire
his Philippine citizenship would not even required to file a petition in court; all he had to do is to take an
Oath of Allegiance to the Republic of the Philippines and to register the said oath with the proper civil
registry.