MOYA LIM YAO VS.

COMM ON IMIGRATION 41 SCRA 292

Under Sec. 15 of Commonwealth Act 473, an alien woman marrying a Filipino, native
born or naturalized, become ipso facto a Filipina provided she is not disqualified to be a citizen of
the Philippines under Sec. 4 of the same law. Likewise, an alien woman married to an alien who
is subsequently naturalized here follows the Philippines citizenship of her husband the moment
he takes his oath as Filipino citizen, provided that she does not suffer from any disqualifications
under said Sec. 4. “Ipso Facto” as here use does not mean that all alien wives and all minor
children of Philippine citizens, from the mere fact of relationship, necessary become such
citizens also. Those who do not meet the statutory requirements do not ipso facto become
citizens; they must apply for naturalization in order to acquire such status. Under the second
paragraph of Sec. 15, a minor child of a Filipino naturalized under the law, who was born in the
Philippine, becomes ipso facto a citizen of the Philippines from the time the fact of relationship
concurs with the fact of a citizenship of his parent, and the time when child become a citizen
does not depend upon the time that he is able to prove