G.R. No. L-21289. October 04, 1971 (Case Brief / Digest)

**Title: Moy Ya Lim Yao, alias Edilberto Aguinaldo Lim, and Lau Yuen Yeung v. The Commissioner of Immigration**

On February 8, 1961, Lau Yuen Yeung, a Chinese national from Hong Kong, applied for a temporary visitor’s visa to the Philippines, stating her intent to visit her grand-uncle, Lau Ching Ping, for one month. She entered the Philippines on March 13, 1961, with her stay initially set to expire on April 13, 1961. Asher Y. Cheng filed a P1,000.00 bond to ensure her departure within her authorized stay, which was later extended to February 13, 1962. On January 25, 1962, she married Moy Ya Lim Yao, alias Edilberto Aguinaldo Lim, an alleged Filipino citizen. However, impending actions from the respondent to confiscate her bond and order her arrest and immediate deportation led her to file an action for injunction with preliminary injunction.

Despite the denial of the preliminary injunction, the case was heard on merits. Lau Yuen Yeung’s inability to write or effectively communicate in English or Tagalog, coupled with her unfamiliarity with local culture and relations, was noted. Based on these facts, the Court of First Instance of Manila, in Civil Case No. 49705, decided that the petition for injunction could not be sustained, referencing Section 15 of the Revised Naturalization Law among its reasons.

1. Whether an alien woman married to a Filipino citizen automatically acquires Philippine citizenship.
2. The application of Section 15 of the Revised Naturalization Law to Lau Yuen Yeung’s case.
3. The implications of marrying a Filipino citizen just before the expiry of Lau Yuen Yeung’s authorized stay in the Philippines.
4. The effect of Lau Yuen Yeung’s marriage on her status as a temporary visitor and her subsequent application for citizenship.

**Court’s Decision:**
The Supreme Court upheld the decision of the lower court, emphasizing the conditions under which an alien woman married to a Filipino could be deemed a Philippine citizen. It iterated that mere marriage to a Filipino does not automatically confer Philippine citizenship upon the alien spouse. The alien spouse must possess all the qualifications and none of the disqualifications prescribed by the Philippine Naturalization Laws. Moreover, the Court highlighted that an alien admitted as a non-immigrant cannot claim to remain in the Philippines permanently without first complying with the requirements for changing status from non-immigrant to immigrant or citizen.

The key doctrine established is that an alien woman may be deemed a citizen of the Philippines by virtue of her marriage to a Filipino citizen only if she possesses all the qualifications and none of the disqualifications specified by law. Additionally, an alien admitted as a non-immigrant must undergo the legal process for changing their status to permanently reside in the country.

**Class Notes:**
– The alien spouse of a Filipino citizen must meet all qualifications and have none of the disqualifications under the Naturalization Law to be considered a Philippine citizen.
– Marriage to a Filipino citizen alone does not automatically grant citizenship to an alien spouse.
– Non-immigrant aliens cannot remain in the Philippines permanently without legally changing their immigration status.
– Relevant statutes: Revised Naturalization Law, Section 15; Philippine Immigration Act of 1940, Section 9(g).

**Historical Background:**
The case underscores the intricacies of Philippine immigration and naturalization laws, particularly concerning the status of alien spouses of Filipino citizens. It highlights the legal challenges faced by mixed-nationality marriages and the stringent requirements for an alien spouse seeking Philippine citizenship. This reflects the broader context of post-colonial Philippines navigating its sovereignty and the complexities of national identity and citizenship in the context of international relations and domestic law.


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