4/14/2021
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Naturalization may be either administrative, judicial, or legislative. As the name
implies, administrative naturalization is the grant of Filipino citizenship to aliens via
administrative proceedings and is currently governed by Republic Act No. 9139.[68]
Judicial naturalization grants Filipino citizenship through a judicial decree and is
governed by Commonwealth Act No. 423 or the Revised Naturalization Law, as
amended.[69] Lastly, legislative naturalization bestows Filipino citizenship through a
statute enacted by Congress.[70]
It is undisputed that Winston Brian, Christopher Troy, and Jon Nicholas' father, Lao Kian
Ben, applied for naturalization under Letter of Instructions No. 270, and his application
was granted under Presidential Decree No. 923. Presidential Decree No. 923 provided
for the same rights, privileges, duties, and obligations as well as conditions and effects
of naturalization as those provided in Presidential Decree No. 836. The pertinent
provisions of Letter of Instructions No. 270 and Presidential Decree No. 836 are as
follows:
LETTER OF INSTRUCTIONS NO. 270
TO
:
Solicitor General
Undersecretary of Foreign Affairs
Director General NISA
SUBJECT
:
Naturalization of Deserving Aliens by
Decree
In order that aliens permanently residing in this country who, having
developed and demonstrated love for and loyalty to the Philippines and
affinity to the customs, traditions and ideals of the Filipino people, as well as
contributed to the economic, social and cultural development of our country,
may be integrated into the national fabric by the grant of Philippine
citizenship, you are hereby directed as follows:
1. That you shall constitute yourself as a Committee, with the Solicitor
General as Chairman, to receive, and consider and submit recommendations
on, applications for naturalization by decree from aliens with the following
qualifications and none of the following disqualifications:
Qualifications:
a. He must not be less than 21 years of age on the date of
the filing of his petition;
b. If born in a foreign country, he must have been legally
admitted into the Philippines either as an immigrant or
a non-immigrant;
c. He must have had a continuous residence in the
Philippines of ten years, which period shall be reduced
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66236
10/20