ROA DOCTRINE (Roa v.

Collector of Customs; jus soli principle; facts: alien parent with a child born in the
Phils. But bec. Of the death of alien father, the child acquires that of her mothers citizenship; Ruling: roa
declared Filipino citizen by virtue of jus soli) Tan Chong case (overruled Roa case; abandoned the jus
soli principle; jus soli would encourage dual allegiance; jus soli was never extended in our jurisdiction;
reckoning pt: should be spanish citizen on Apr. 11, 1899 to confer citizenship to the child and be deemed
a Filipino subject; Phil bill 1902 applies; res judicata still applicable) Tio Tiam v. Republic (roa doctrine
abandoned; Tan Chong case upheld; no judicial pronouncement before the overruling of roa doctrine;
THE SC required that there must be conferment by the courts or judicial declaration prior to the
overruling of Roa)

My conclusion: those benefited by the roa doctrine applying the jus soli principle are FILIPINO citizens.
That is why, Tan Chong and Tio Tiam could not be declared Filipino citizens because Phil Bill of 1902
applies, i.e., inhabitants of the Philippine Islands continuing to reside therein who were Spanish
subjects on the 11th day of April 1899, and then resided in said islands, and their children born
subsequent theretom, shall be deemed and held to be citizens of the Philippine Islands. They need
judicial declaraiton pursuant to the dcision of Tan Chong.

So, retain natin si letter (b) pero may notation derived from the first paragprah na abandoned na siya
pero dahil may res judicata doctrine, di affected ung na benefit ng roa doctrine. Pero subseqt sa Tan
Chong case, di na magaapply si Roa doctrine, UNLESS there was judicial declaration that they were
conferred Filipino citizenship.

Sa letter (c) naman, naturalization under Act 2927, as amended by Act 3448 was repealed na nga. Pero
considered Filipinos pa din ung naconfer ng statutes na yan. Lets note na lang na this law is repealed
but without prejudice to those benefitted thereof.