G.R. No. L-17318, December 29, 1962
IN THE MATTER FOR NATURALIZATION AS PHILIPPINE CITIZEN. ANTONIO GO KAY SEE, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

On April 12, 1956, Antonio Go Kay See filed a petition for naturalization with the Court of First Instance of Isabela. After due publication and hearing, the court rendered a decision on November 25, 1957, granting his application. The decision ordered the issuance of a naturalization certificate after the mandatory two-year probationary period under Republic Act No. 530 . On December 21, 1959, petitioner filed a motion alleging compliance with the statutory conditions during the intervening period from November 25, 1957, to January 6, 1960, and prayed for the registration of the decision and the taking of his oath.
The provincial fiscal filed an opposition, contending that petitioner failed to pay his annual alien registration fees for the years 1958 and 1959, which constituted a violation of government-announced policy requiring aliens to register annually with the Bureau of Immigration. The lower court rejected this opposition, accepting petitioner’s explanation that his failure was due to an honest belief he was exempt because his Alien Certificate of Registration had been presented as an exhibit in court. Consequently, the court issued an order on June 3, 1960, directing the issuance of the naturalization certificate, prompting the present appeal by the Republic.

ISSUE

Whether petitioner’s failure to pay his annual alien registration fees during the two-year probationary period disqualifies him from taking the oath as a naturalized citizen under Republic Act No. 530 .

RULING

The Supreme Court reversed the lower court’s order and set aside the naturalization decision. The legal logic is anchored on the strict statutory requirements of Republic Act No. 530 , which governs the finality of naturalization decisions. The law explicitly bars a decision from becoming executory if, within the two-year probationary period, the applicant has committed any act contrary to any government-announced policy. The annual alien registration is a clear and mandatory government policy imposed on all aliens.
The Court held that petitioner’s admitted failure to register for 1958 and 1959 constituted a patent violation of this policy. The two-year period is designed as a crucial test of the applicant’s continued fitness and adherence to Philippine laws. Compliance must be exact and unwavering. The excuse of an “honest belief” in exemption is immaterial and unacceptable; ignorance of the law excuses no one, especially an applicant for citizenship who is expected to demonstrate scrupulous obedience. Allowing such a flimsy excuse would undermine the integrity of the naturalization process and the State’s guarantee that only fully qualified individuals are granted citizenship. Therefore, petitioner failed the statutory test, warranting the denial of his naturalization.