4/14/2021
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Naturalization—Winston Brian, Christopher Troy, and Jon Nicholas co tend that Co long
resolved the issue in the affirmative. The father in Co was naturalized under Letter of
Instructions No. 270, the same presidential decree under which Winston Brian,
Christopher Troy, and Jon Nicholas' father applied for naturalization. Letter of
Instructions No. 270, according to the Court in Co, is in pari materia with Section 15[53]
of Commonwealth Act No. 473 or the Revised Naturalization Law, which automatically
granted Philippine citizenship to the minor children of the naturalized Filipino under
certain conditions. In their case, Winston Brian, Christopher Troy, and Jon Nicholas
argue that that they have established these essential facts: (1) that their father was
naturalized under Letter of Instruction No. 270; (2) that they were born in the
Philippines; and (3) that they were minors at the time their father was granted
Philippine citizenship. Thus, pursuant to Letter of Instructions No. 270 in relation to
Section 15 of Commonwealth Act No. 473, they should likewise be deemed Filipinos.[54]
As to whether a proceeding should first be conducted by the Special Committee on
Naturalization to determine whether Winston Brian, Christopher Troy, and Jon Nicholas
indeed satisfied the requirements for naturalization under Section 15 of Commonwealth
Act No. 473, Winston Brian, Christopher Troy, and Jon Nicholas argue that they never
disputed the Special Committee on Naturalization's jurisdiction over administrative
proceedings for acquiring Philippine citizenship.[55] However, they maintain that the
issue of whether a proceeding should first be conducted is irrelevant in this case.
Specifically for respondent Jon Nicolas, he effectively maintains that the Special
Committee on Naturalization is already estopped from claiming that a proceeding
should first be conducted since it actively participated as a witness for Winston Brian,
Christopher Troy, and Jon Nicholas before the trial court.[56]
The consolidated Petitions for Review on Certiorari are denied. The Manila and Quezon
City trial courts correctly granted the Petitions for Correction filed by Winston Brian,
Christopher Troy, and Jon Nicholas.
I
Births are among those events required to be entered in the civil register.[57] The
certificate of live birth or birth certificate, a vital record contained in the birth and death
register, establishes the fact of birth. The required entries in the certificate of live birth
are provided in Section 5 of Act No. 3753, thus:
SECTION 5. Registration and Certification of Births. — The declaration of the
physician or midwife in attendance at the birth or, in default thereof, the
declaration of either parent of the newborn child, shall be sufficient for the
registration of a birth in the civil register. Such declaration shall be exempt
from the documentary stamp tax and shall be sent to the local civil registrar
not later than thirty days after the birth, by the physician, or midwife in
attendance at the birth or by either parent of the newly born child.
In such declaration, the persons above mentioned shall certify to the
following facts: (a) date and hour of birth; (b) sex and nationality of infant;
(c) names, citizenship, and religion of parents or, in case the father is not
known, of the mother alone; (d) civil status of parents; (e) place where the
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66236
6/20