The Applicant, after having completed a Bachelor of Laws course, filed an application to

take the 1998 Bar Examinations. He was allowed by the SC to take the Bar
Examinations, subject to the condition that he must submit to the Court proof of his
Philippine citizenship. In compliance with the Courts resolution, the Applicant submitted
on November 18, 1998 the documents required for him to be allowed to take the Bar
Examinations.
On April 5, 1999, the results of the 1998 Bar Examinations were released and the
Applicant was one of the successful Bar examinees and was scheduled to take the oath on
May 5, 1999. However, because of the questionable status of the Applicant's citizenship,
he was not allowed to do so. The Court required him to submit further proof of his
citizenship. In the same resolution, the OSG was required to comment on the Applicant's
petition for admission to the bar and on the document he had submitted evidencing his
Philippine citizenship.
The OSG pointed out that the Applicant had not formally elected Philippine citizenship
and, if he ever did, it would already be beyond the "reasonable time" allowed by present
jurisprudence. It recommended the relaxation of the phrase "reasonable period" and the
allowance of the Applicant to elect Philippine citizenship in accordance with C.A. No.
625 prior to taking his oath as a member of the Philippine Bar.
The Applicant adhered to the comment and submitted documents to elect Philippine
citizenship. The question raised thereafter was whether he had elected Philippine
citizenship within a "reasonable time."
Although, the 1935 Constitution provided that the Applicant was a Chinese citizen, it did
not prescribe a time period within which the election of Philippine citizenship should be
made The 1935 Charter only provides that the election should be made "upon reaching
the age of majority."
However, based on the pronouncements of the Department of State of the United States,
the phrase "reasonable time" has been interpreted to mean that the election should be
made within three (3) years from reaching the age of majority. However, the court, in one
of its decisions, held that it should "be extended under certain circumstances.
The Applicant, in the present case, was already thirty-five years old when he complied
with the requirements of the law over fourteen years after he had reached the age of
majority, and it was way beyond the allowable period within which to exercise the
privilege.
The Court denied the petition stating that the span of fourteen (14) years that lapsed from
the time he reached the age of majority until he finally expressed his intention to elect
Philippine citizenship is clearly way beyond the contemplation of the requirement of
electing "upon reaching the age of majority..