REPUBLIC OF THE PHILIPPINES v. BATUIGAS (TRINA) land in Barrio Lombog, Margosatubig.
October 7, 2013 | Del Castillo, J. | Natural-born citizens and public office 5. The RTC found that Azucena had amply supported the allegations in her
Petition, and granted the petition.
PETITIONER: Republic of the Philippines 6. OSG argued the ex-parte presentation of evidence before the Branch Clerk
RESPONDENT: Azucena Saavaedra Batugas of Court violates Section 10 of CA 473, as the law mandates public hearing
in naturalization cases.
SUMMARY: Azucena filed a Petition for Naturalization before the RTC of 7. CA dismissed the OSG’s appeal and found that Azucena’s financial
Zamboanga del Sur. OSG filed a motion to dismiss alleging that she had not condition permits her and her family to live with reasonable comfort in
complied with the existing laws, particularly Section 10 of CA 473. However, accordance with the prevailing standard of living and consistent with the
SC ruled in favor of Azucena. (see doctrine) demands of human dignity.
DOCTRINE: Under existing laws, an alien may acquire Philippine citizenship ISSUE/s:
through either judicial naturalization under CA 473 or administrative 1. Whether or not petitioner has validly complied with the citizenship
naturalization under Republic Act No. 9139 (the "Administrative Naturalization requirement as required by law to become a naturalized citizen of the
Law of 2000"). A third option, called derivative naturalization, which is Philippines. – YES
available to alien women married to Filipino husbands is found under Section
15 of CA 473, which provides that: RULING: SC granted the petition.
"any woman who is now or may hereafter be married to a citizen of the RATIO:
Philippines and who might herself be lawfully naturalized shall be deemed a
citizen of the Philippines." 1. See doctrine.
2. Under this provision, foreign women who are married to Philippine citizens
may be deemed ipso facto Philippine citizens and it is neither necessary for
FACTS: them to prove that they possess other qualifications for naturalization at the
1. In December 2002, Azucena filed a Petition for Naturalization before the time of their marriage nor do they have to submit themselves to judicial
RTC of Zamboanga del Sur. naturalization. Copying from similar laws in the United States which has
2. Azucena alleged in her petition that she believes in the principles since been amended, the Philippine legislature retained Section 15 of CA
underlying the Philippine Constitution, among others. After all the 473, which then reflects its intent to confer Filipino citizenship to the alien
jurisdictional requirements mandated by Sec. 9 of the Commonwealth Act wife thru derivative naturalization.
473 had been complied with, the OSG filed its motion to dismiss on the 3. No. 4, Section 2 of CA 473 provides as qualification to become a Philippine
ground that Azucena failed to allege that she is engaged in a lawful citizen: 4. He must own real estate in the Philippines worth not less than
occupation or in some known lucrative business. RTC ruled in favor of the five thousand pesos, Philippine currency, or must have known lucrative
OSG. Thereafter, the hearing for the reception of Azucena’s evidence was trade, profession, or lawful occupation.
then set on May 18, 2004. 4. Azucena is a teacher by profession and has actually exercised her profession
3. The evidence presented that Azucena has never departed from before she had to quit her teaching job to assume her family duties and take
the Philippines since birth. She resided in Zamboanga del Sur up to the on her role as joint provider, together with her husband, in order to support
filing of her petition. She married Santiago Batuigas, a natural born Filipino her family. Together, husband and wife were able to raise all their five
citizen. They have 5 children, all who studied in Philippine public and children, provided them with education, and have all become professionals
private schools, and are now professionals. and responsible citizens of this country. Certainly, this is proof enough of
4. The spouses Batuigas were engaged in the business of and later on in both husband and wife’s lucrative trade. Azucena herself is a professional
milling/distributing rice, corn, and copra. As proof of their income, and can resume teaching at anytime. Her profession never leaves her, and
Azucena submitted their joint annual tax returns and balance sheets. The this is more than sufficient guarantee that she will not be a charge to the
business name and the business permits issued to the spouses’ store, only country she has known since birth.
‘Azucena’s General Merchandising,’ are registered in Santiago’s name, and 5. Moreover, the Court acknowledged that the main objective of extending the
he is also the National Food Authority licensee for their rice and corn citizenship privilege to an alien wife is to maintain a unity of allegiance
business. During their marital union, the Batuigas spouses bought parcels of among family members, thus:
6. It is, therefore, not congruent with our cherished traditions of family unity
and identity that a husband should be a citizen and the wife an alien, and
that the national treatment of one should be different from that of the other.
Thus, it cannot be that the husband’s interests in property and business
activities reserved by law to citizens should not form part of the conjugal
partnership and be denied to the wife, nor that she herself cannot, through
her own efforts but for the benefit of the partnership, acquire such interests.
Only in rare instances should the identity of husband and wife be refused
recognition, and we submit that in respect of our citizenship laws, it should
only be in the instances where the wife suffers from the disqualifications
stated in Section 4 of the Revised Naturalization Law.
