ANGAT vs.

REPUBLIC, 314 SCRA 438 (1999)

Definition of citizenship

FACTS:
Petitioner Gerardo Angat was a natural born citizen of the Philippines until he lost his
citizenship by naturalization in the United States of America. On March 11, 1996 Angat filed
a petition with RTC Marikina to be re-admitted as a Citizen of the Philippines (under
Commonwealth Act No. 63, RA 965. After hearing, Angat was allowed by RTC to take his
oath of allegiance to the Republic of the Philippines pursuant to R.A. 8171. OSG opposed the
petition contending that RTC has no jurisdiction because the proper forum was the Special
Committee on Naturalization consistently with AO 285.

ISSUE:
Whether or not the Solicitor General was correct in contending that RTC has no
jurisdiction and that the petition should have been filed with the Special Committee on
Naturalization.

RATIO:
The Office of the Solicitor General was right in maintaining that Angat's petition should
have been filed with the Committee, and not with the RTC which had no jurisdiction. It should
also be noteworthy that the petition was one for repatriation, and it was thus incorrect for
petitioner to initially invoke Republic Act No. 965 and R.A. No. 2630 since these laws could
only apply to persons who had lost their citizenship by rendering service to, or accepting
commission in, the armed forces of an allied foreign country or the armed forces of the United
States of America, a factual matter not alleged in the petition. Under these statutes, the person
desiring to re-acquire Philippine citizenship would not even be required to file a petition in
court, and all that he had to do was to take an oath of allegiance to the Republic of the
Philippines and to register that fact with the civil registry in the place of his residence or where
he had last resided in the Philippines.