GR 25700; (January, 1971) (Digest)
G.R. No. L-25700. January 30, 1971.
IN THE MATTER OF THE PETITION FOR NATURALIZATION AS CITIZEN OF THE PHILIPPINES. JOSE UY, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Petitioner Jose Uy filed a petition for naturalization in the Court of First Instance of Negros Occidental, which was granted. The Republic appealed, contending that Uy failed to meet the stringent legal requirements. The petition was materially defective. It omitted his six-year residence in Dumaguete City from 1951 to 1956, where he completed his high school and college education at Silliman University. It also failed to include his other known aliases, such as Jose T. Uy and Jose Uy, Sr., which appeared in vital documents like his marriage contract, his children’s birth certificates, and his academic diplomas. Furthermore, the published notice of hearing did not reproduce the petition verbatim, as required by law, as it omitted specific allegations regarding his residence in Iloilo City, his good moral character, and his claim of exemption from filing a declaration of intention.
ISSUE
Whether the trial court erred in granting Jose Uy’s petition for naturalization despite fatal deficiencies in his petition, notice of hearing, proof of lucrative income, and the competency of his character witnesses.
RULING
The Supreme Court reversed the trial court’s decision and dismissed the petition. The legal logic is anchored on the mandatory and strict compliance required in naturalization proceedings. First, the petition’s substantive flaws—the omission of a significant six-year residence and the failure to state all names used—violate the statutory requirement for a complete and truthful disclosure of all material facts. Second, the notice of hearing’s failure to restate the petition verbatim, by omitting key allegations, is a fatal jurisdictional defect. The Court has consistently ruled that such an omission deprives the public of proper notice and nullifies the proceedings.
Regarding income, Uy failed to prove by clear and convincing evidence that he had a lucrative trade or occupation. His testimony about his employment and salary was inconsistent with and uncorroborated by his income tax returns, which listed different employers and amounts. His claims about the value of housing and utility benefits were self-serving and unsupported by objective evidence. Finally, one character witness, Antonio Ko, was not established to be a competent Filipino citizen witness. Ko failed to present indubitable documentary proof of his Filipino citizenship and, as a resident living 60 kilometers away who saw Uy only intermittently, he could not possess the continuous personal knowledge of Uy’s conduct and character throughout the requisite statutory period. These cumulative failures to meet the exacting standards of the naturalization law warranted the denial of the petition.