Hubert Tan Co & Arlene Tan Co vs. Civil Register of Manila, G.R. No. 467, Phil. 904 (1998)
**Facts:**
1. **Birth and Citizenship**: Hubert Tan Co was born on March 23, 1974, and Arlene Tan Co on May 19, 1975, in the Philippines. Their birth certificates listed their parents, Co Boon Peng and Lourdes Vihong K. Tan, as Chinese citizens.
2. **Father’s Naturalization**: Co Boon Peng applied for naturalization under LOI No. 270 and was granted Philippine citizenship under Presidential Decree No. 1055. He took his oath as a Philippine citizen on February 15, 1977.
3. **Petition for Correction**: On August 27, 1998, Hubert and Arlene Tan Co filed a petition under Rule 108 of the Rules of Court with the Regional Trial Court (RTC) of Manila, seeking to correct their birth certificates to reflect their father’s citizenship as “Filipino” instead of “Chinese.”
4. **RTC Orders**: The RTC dismissed the petition on September 23, 1998, stating it was insufficient because their father obtained citizenship under LOI No. 270, not under Commonwealth Act No. 473.
5. **Motion for Reconsideration**: The petitioners filed a motion for reconsideration that the RTC denied on April 27, 1999, maintaining that LOI No. 270 did not extend benefits to the children of naturalized individuals like CA No. 473.
**Issues:**
1. **Interpretation of Statutes in Pari Materia**: Whether LOI No. 270 and CA No. 473 should be construed together, implying that Section 15 of CA No. 473 (which provides citizenship to minor children of naturalized individuals) applies to those naturalized under LOI No. 270.
2. **Appropriateness of Rule 108 Proceedings**: Whether the correction of the birth certificates through Rule 108 was proper.
3. **Applicability of Article 407 of the Civil Code**: Whether the naturalization of the petitioners’ father, post their birth, qualifies as an act affecting their civil status that should be recorded.
**Court’s Decision:**
1. **Statutes in Pari Materia**: The Court found that LOI No. 270 and CA No. 473 serve the same legislative purpose of granting Filipino citizenship to qualified aliens and thus should be read together. Section 15 of CA No. 473, which extends citizenship to minor children of naturalized individuals, applies equally to those naturalized under LOI No. 270.
2. **Rule 108**: The RTC improperly dismissed the petition outright without following procedural requirements under Rule 108. The Court ruled that Rule 108 could be used for substantial corrections like changes in nationality, provided due process (notice and hearing) is observed.
3. **Article 407**: The Court agreed with the petitioners that the naturalization of their father is an event concerning their civil status that should be recorded in the Civil Register.
**Doctrine:**
The doctrine established is that statutes in pari materia, which relate to the same subject and share common purposes, should be read and construed together unless an express repeal or clear inconsistency exists. Moreover, substantial corrections in civil registry entries, including changes in nationality status due to naturalization, can be pursued under Rule 108 of the Rules of Court, observing due procedure.
**Class Notes:**
– **Statutes in Pari Materia**: CA No. 473 and LOI No. 270 should be read together, implying unified legislative intent.
– **Rule 108, Rules of Court**: Allows for changes in civil status entries, including nationality, provided procedural due process is followed.
– **Article 407, Civil Code**: Acts affecting the civil status of individuals, such as naturalization, must be recorded in the Civil Register.
**Key Elements:**
– **Naturalization**: Legal act of granting citizenship to an alien.
– **Relevant Provisions**:
– Sec. 15, Commonwealth Act No. 473: Extends citizenship to minor children of naturalized individuals.
– LOI No. 270: Another statute for naturalization, emphasizing expeditious procedures.
– **Application**: Both statutes serve a common purpose and must be harmonized.
**Historical Background:**
The case emerges from the broader historical context of the Philippines adjusting immigration, naturalization laws, and integrating qualified aliens. LOI No. 270 was issued under a martial law regime aiming to streamline the naturalization process to reward and expedite granting citizenship to resident aliens who contribute to national development. The case underscores judicial efforts to reconcile procedural disparities in naturalization pathways, reflecting evolving legislative intent to integrate deserving aliens and their families into Philippine society.
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