1, PEOPLE – INHABITANTS

TOPIC: Sec. 1, Art. III, Bill of Rights

CASE FACTS ISSUE RULING

QUA -Petitioners purchased US Dollars without necessary Whether the right given to the Yes. The Court held that the right of an individual to be secure in his person is
CHEE license from Central Bank and deposited to Hongkong “people” against warrantless guaranteed by the Constitution, and indisputably equally applies to both citizens
GAN V and attempting to bribe of Phil & US Govt to evade arrest under Article 3 of the and foreigners
DEP prosecution Constitution, also applies to
BOARD foreigners.

2. CITIZENSHIP

A. IMPORTANCE

LEE V DIL Petitioners, heirs of Lee Liong, sought reconstitution of Whether petitioners may own Yes. The Court held that The constitutional proscription on alien ownership of
title of a parcel of land in the name of Lee Liong whose land in the Philippines lands of the public or private domain was intended to protect lands from falling
transfer certificate of title was destroyed. At the trial in the hands of non-Filipinos. In this case, however, there would be no more
they presented documents proving the sale of land from public policy violated since the land is in the hands of Filipinos qualified to
the Dingsalans to Lee Liong. The Dingsalans, however acquire and own such land. "If land is invalidly transferred to an alien who
claimed that Lee Liong, a Chinese citizen, was subsequently becomes a citizen or transfers it to a citizen, the flaw in the original
disqualified under the Constitution to acquire the land in transaction is considered cured and the title of the transferee is rendered valid."
question. However, the petitioners who are hiers of Lee Thus, the subsequent transfer of the property to qualified Filipinos may no longer
Liong have already become Filipino citizens. be impugned on the basis of the invalidity of the initial transfer. The objective of
the constitutional provision to keep our lands in Filipino hands has been
achieved.
MABANA Colonels accepted payment from respondent Ramona for Whether petitioner has No. The Court held that the petitioner was not the proper party to challenge
GV the purchase of a house and lot. Later however, the capacity to challenge the Ramona’s qualifications to acquire land. Only the Government, through the
REGISTE colonels sold the property to petitioner for a higher capacity of a person to own a Solicitor General, has the personality to file a case challenging the capacity of a
R price. Respondent filed a complaint for specific land based on non-citizenship. person to acquire or to own land based on non-citizenship. This limitation is
performance and damages, and the RTC ruled in her based on the fact that the violation is committed against the State, not against
favor, the CA then affirmed RTC’s decision. Now, any individual; and that in the event that the transferee is adjudged to be not a
petitioners seeks to assail the capacity of respondent to Filipino citizen, the affected property reverts to the State, not to the previous
own the land, alleging that her citizenship is in question. owner or any other individual.

B. WHO ARE PHILIPPINE CITIZENS

TECSON Respondent Allan Kelly Poe(a.k.a Fernando Poe, Jr.) ran Whether illegitimate children No. The Court held that under the 1935 Constitution, during which regime
V for president. Petitioner sought to disqualify FPJ and of a Filipino father and an respondent FPJ has seen first light, confers citizenship to all persons whose
COMELE cancel his certificate of candidacy, alleging that FPJ alien mother cannot gain the fathers are Filipino citizens regardless of whether such children are legitimate or
C misrepresented himself as a natural-born Filipino citizen, Philippine citizenship of the illegitimate.
petitioner alleged that FPJ’s mother, Bessie Kelley, was father.
an American, while his father, Allan Poe, was a Spanish
national, because Allan Poe’s father (FPJ’s grandfather)
was a Spanish subject.
RP V Respondent Chule Y. lim petitioned for correction of her Whether respondent is a Yes. The Court held that the constitutional and statutory requirement of electing
CHULE records of birth, she claimed that her nationality was natural born Filipino citizen Filipino citizenship apply only to legitimate children. They do not apply to
LIM entered as Chinese when it should have been Filipino, respondent was an illegitimate child. As such, she was not required to comply
with said constitutional and statutory requirements to become a Filipino citizen.
By being an illegitimate, child of a Filipino mother, respondent automatically
became a Filipino upon birth, without having to elect Filipino citizenship when
she reached the age of majority.
GONZAL Respondent Pennisi was born on March 13, 1975, in Whether res judicata applies No. The Court held that the issuance of certificate of recognition to respondent
ES V Australia to Alfio Pennisi, an Australian national, and to citizenship proceedings. has not attained finality. The Court ruled that citizenship proceedings are a class
PENNISI Anita Quintos, allegedly a Filipino citizen. Respondent (Whether the issue of of its own, and can be threshed out again and again as the occasion may
then filed a petition for recognition as Filipino citizen citizenship, once decided demand.
before the Bureauof Immigration(BI). Bureau of upon by a competent court, Hence, as a general rule, res judicata does not apply to citizenship proceedings.
Immigration granted respondent’s petition for becomes final and cannot be Res judicata may only be applied in cases of citizenship if: 1). A person’s
recognition as a Filipino citizen, brought up again). citizenship must be raised as a material issue in a controversy where said person
a Senate investigation was conducted, which is a party; the solicitor general or his authorized representative took active part
 recommended the deportation of Respondent, which in the resolution thereof; and the finding or citizenship is affirmed by this court.
found that the authenticity of the birth certificate of his Pennisi is a Filipino Citizen. Evidence presented before BI and DOJ have
mother was suspicious. Pennisi argued that when he probative value. While Affidavit of petitioners might have case doubt on validity
filed the petition for recognition was already final and of birth certificate, docs remain valid unless declared invalid by competent
the principle of res judicata applies. authority.

C. ELECTION OF PHILIPPINE CITIZENSHIP