CASE DIGEST: Pardo v. Republic

 


Pardo vs. Republic
G.R. No. L-2248. January 23, 1950.

 

FACTS:

Vicente Rosal Pardo is a Spanish citizen born in Spain in 1895 and is residing in the Philippines since 1905. He married a Filipina and at the time of this case was employed in Manila. He was adjudged by the CFI of Manila entitled to become a Filipino citizen.  The government appealed on the ground, among others,  that Pardo is unable to speak and write any of the principal Filipino languages..

Pardo also introduced a certificate signed by the Consul General of Spain in the Philippines, stating that in accordance with articles 17 and 25 of the Spanish Civil Code, among other Spanish legislation, Filipinos are eligible to Spanish citizenship in Spain. Article 17 provides that foreigners who have obtained a certificate of naturalization and those who have not obtained such certificate but have acquired domicile in any town of the Monarchy are Spaniards. No discrimination being made in these provisions, they apply to persons of any nationality.

ISSUE:

Whether or not Filipinos being eligible to Spanish citizenship in Spain is a matter within judicial notice

RULING:

YES.

As the Spanish Civil Code has been and still is "the basic code in force in the Philippines," articles 17 et seq. thereof may be regarded as matters known to judges of the Philippines by reason of their judicial functions and may be judicially recognized by them without the introduction of proof. Moreover, in a number of decisions mere authentication of the Chinese Naturalization Law by the Chinese Consulate General of Manila has been held to be competent proof of that law.

MR:

YES.

Accordingly, evidence of the law of a foreign country on reciprocity regarding the acquisition of citizenship, although not meeting the prescribed rule of practice by section 41 of Rule 123, may be allowed and used as basis for a favorable action if, in the light of all the circumstances, the court is satisfied of the authenticity of the written proof offered.

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