The Doctrine in Ching Leng v.

Galang

The prevailing doctrine today is that an illegitimate child of a Filipino father and an alien mother
follows the citizenship of the alien mother as the only legally known parent. The illegitimate
child, even if acknowledged and legally adopted by the Filipino father, cannot acquire the
citizenship of the father. The Court made this definitive doctrinal ruling in Ching Leng v.
Galang,[33] which involved the illegitimate minor children of a naturalized Filipino of Chinese
descent with a Chinese woman, Sy An. The illegitimate children were later on jointly adopted by
the naturalized Filipino and his legal wife, So Buan Ty.