Roa vs. Collector of Customs, 25 Phil 315
Petitioner-Appellant:
Tranquilino Roa
Respondent-Appellee:
Insular Collector of Customs
Facts:
Tranquilino, born on July 6, 1889, is the son of a Chinaman and a Filipina legally
married in the Philippine Islands at the time of his birth. His mother sent him to China
on 1901, just a year after his father died in China, for the sole purpose of studying and
with the intention to return to the Philippine Islands. On October 1, 1910, when
Tranquilino was 21 years of age, he returned and sought admission to the Philippine
Islands but was denied such for he was considered as a Chinese person.
Issue:
Whether or not Roa is considered a citizen of the Philippines.
Held:
Yes, Roa is a citizen of the Philippines. Since Philippines at that time was ceded
to the United States, the allegiance of native inhabitants was transferred from Spain to
US, thus the principle of citizenship of US must be applied in the case at bar since
Spanish laws were deemed abrogated. In US, the predominating principle is jus soji or
citizenship by place of birth. The rule in US in case of widows was that she ipso
facto reacquired the nationality of the country of her birth as she was living and never
left that country. The nationality of the appellant having followed that of his mother, he
was therefore a citizen of the Philippine Islands on July 1, 1902, and never having
expatriated himself, he still remains a citizen of this country.
Teotimo Rodriguez Tio Tiam vs. Republic, 101 Phil 195
Petitioner-Appellee:
Teotimo Rodriguez Tio Tiam
Oppositor-Appellant:
Republic of the Philippines
Facts:
Teotimo was born in Cebu City of Chinese parents and married to a Chinese
woman. He also voted in various elections held and had took the oath of allegiance as a
citizen of the Philippines. The petitioner showed evidences that rendered him qualified
to be a Filipino citizen but the government argued that he was disqualified for having
an alleged illicit relation that questions his possession of good moral character, which
was not substantially proven.
Issue:
Whether or not Teotimo should be declared a Filipino citizen.
Held:
Yes, Teotimo is considered a Filipino citizen through the naturalization law of
the country for the evidentiary fact that qualifies him for the acquisition of Philippine
citizenship. His right to be entitled to Philippines citizenship cannot be affected by mere
hearsay which is rendered incompetent. Petitioner was, then, granted Philippine
citizenship subject to the requirements of Republic Act No. 530.