Anti-Chinese League of the Philippines vs Judge Alfonso Felix

G.R. No. L-998 – 77 Phil. 1018 – Remedial Law – Civil Procedure – Real Party in Interest; Naturalization Case

Sometime in the 1940s, a certain Chinese citizen named Teodoro Lim filed a petition for naturalization for him to become a Filipino citizen. The Anti-Chinese League of the Philippines (ACL) filed their motion to intervene in the said naturalization proceeding but Judge Alfonso Felix denied their motion on the ground that the group is not a real party in interest. The ACL then filed a petition for mandamus to compel Judge Felix to allow them to intervene.

ISSUE: Whether or not the ACL is a real party in interest.

HELD: No. The petition for mandamus cannot be granted. Judge Felix is right in dismissing the motion to intervene. In the first place, the ACL has no juridical entity (ACL is not registered). Only natural or juridical entities may be parties to a case. But even if ACL is registered, it still cannot be made a party to the case at bar. Naturalization is indeed a case which is imbued with public interest. However, only the government, through the Solicitor General, personally or through his delegate, and the provincial fiscal, are the only officers or persons authorized by the law to oppose an application for naturalization or move for the cancellation of a naturalization certificate already issued. The government as an agency of the people represent the public, and therefore the Solicitor-General who appears on behalf of the government represents the public.

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