Rocas, Milliene Ianah R.
Module I
Persons
Republic v. Batuigas
G.R. No. 183110
October 7, 2013
Facts: Before the RTC of Zamboanga del Sur, Azucena submitted a petition for naturalization. Azucena
claimed in her petition that she adheres to the values upheld by the Philippine Constitution and that she had
all of the qualities outlined in Section 2 of Commonwealth Act No. 473, as well as none of the disqualifying
characteristics listed in Section 4. The Office of the Solicitor General (OSG) submitted its Motion to
Dismiss on the grounds that Azucena failed to demonstrate that she is engaged in a legal occupation or in
some other well-known lucrative enterprise after all jurisdictional conditions stipulated by Section 9 of CA
473 had been met. The OSG's arguments were rejected by the RTC on the grounds that they were evidential
in character.
The hearing date for receiving Azucena's testimony was subsequently set for May 18, 2004. On the day of
the hearing, neither the OSG nor the Office of the Provincial Prosecutor showed up. As a result, Azucena's
legal representative requested that the evidence be submitted ex-parte, and the RTC agreed. The RTC
appointed its Clerk of Court as the Commissioner to receive Azucena's evidence as a result. Despite
adequate notice, no OSG representative showed up for the ex-parte hearing. The OSG then filed an appeal,
claiming that Azucena had not complied with the CA 473 income criterion. According to the OSG, Azucena
is not permitted to directly or indirectly engage in the retail trade under the Retail Trade Law (RA No.
1180). The OSG further argued that because ex-parte hearings often take place in chambers without the
public present, the action before the commissioner is not a "public hearing." The CA ruled that Azucena's
financial situation allows her and her family to live in reasonable comfort in accordance with the current
standard of living and commensurate with the requirements of human dignity, therefore rejecting the OSG's
appeal. However, the petitioner-appellee and her Filipino husband were able to support a respectable
lifestyle, send all of their kids to college, and run a successful business. Recent decisions by the Supreme
Court have raised the bar for determining whether a petitioner for Philippine citizenship has a lucrative
trade or profession that would qualify him or her for admission to Philippine citizenship and to which
petitioner has successfully persuaded this Court of her ability to provide for herself and avoid becoming a
public charge or financial burden to her community.
Issue/s: Whether Azucena failed to meet the income and public hearing requirements of CA 473
Ruling: Aliens may currently become citizens of the Philippines through judicial naturalization in
accordance with CA 473 or administrative naturalization in accordance with the "Administrative
Naturalization Law of 2000." Section 15 of CA 473 states that "any woman who is now or may
hereafter be married to a citizen of the Philippines and who might herself be lawfully naturalized
shall be deemed a citizen of the Philippines," and that "an alien woman married to an alien who is
subsequently naturalized here follows the Philippine citizenship of her husband." This third option,
known as derivative naturalization, is open to foreign women married to Filipino husbands under
said Section 4. Azucena has decided to submit a Petition for judicial naturalization under CA 473
in this instance. She should be permitted to apply for judicial naturalization under the same statute
despite the fact that her application for derived naturalization under Section 15 of CA 473 was
rejected. It is important to keep in mind that her application at the CID was rejected because there
was insufficient evidence to support her husband's citizenship, not because she was judged to be
ineligible. In a judicial naturalization hearing, it is appropriate for the courts to decide whether
there are legitimate grounds to refuse her Philippine citizenship based on standard judicial
naturalization procedures, even if the rejection was made on another basis.
The decision of the Court of Appeals is AFFIRMED.