G.R. No. 153986 ; June 8, 2007
IN RE: PETITION FOR ADMISSION AS CITIZENS OF THE PHILIPPINES, SHEWAK A. KESWANI AND KAVITA S. KESWANI, petitioners, vs. REPUBLIC OF THE PHILIPPINES, respondent.

FACTS

Petitioners-spouses Shewak and Kavita Keswani, Indian nationals, filed a joint Amended Petition for naturalization with the Regional Trial Court (RTC) of Makati in 1998. They alleged continuous residence in the Philippines since 1976, ownership of real properties and businesses, annual gross income exceeding two million pesos, good moral character, and the enrollment of their children in a school where Philippine history and civics are taught. After ex parte hearings, the RTC granted the petition and admitted them as Filipino citizens in a Decision dated May 9, 2000.
The Office of the Solicitor General (OSG) filed a Notice of Appeal with the RTC on June 1, 2000. The petitioners moved to dismiss the appeal before the Court of Appeals (CA), arguing it was filed beyond the reglementary period and, more substantially, that under Section 11 of Commonwealth Act No. 473 (the Revised Naturalization Law), appeals in naturalization cases must be filed directly with the Supreme Court. The CA denied the motion to dismiss and eventually rendered a Decision annulling the RTC judgment and dismissing the petition for naturalization, finding the petitioners’ evidence insufficient.

ISSUE

The primary issues are: (1) Whether the Court of Appeals had jurisdiction over the appeal from the RTC’s decision in a naturalization case; and (2) Whether the petitioners successfully discharged the burden of proving they possess all qualifications and none of the disqualifications for naturalization.

RULING

The Supreme Court denied the petition, affirming the CA’s decision. On the jurisdictional issue, the Court held that while Section 11 of C.A. No. 473 originally provided for appeals to the Supreme Court, this procedural rule was superseded by the Judiciary Reorganization Act of 1980 (B.P. Blg. 129), as amended. This law vested the Court of Appeals with exclusive appellate jurisdiction over all final judgments and decisions of regional trial courts, except those falling within the exclusive appellate jurisdiction of the Supreme Court. Naturalization cases do not constitute an exception. Therefore, the OSG correctly appealed to the CA, which properly exercised jurisdiction.
On the substantive issue, the Court sustained the CA’s finding that the petitioners failed to provide sufficient evidence to support their material allegations. The burden of proof in naturalization proceedings rests heavily on the applicant. The Court noted that the petitioners’ evidence consisted mainly of their own testimonies and those of their character witnesses, without corroborating documentary proof. They failed to submit documents such as income tax returns to substantiate their claimed annual income, business registration papers to prove their ownership and control of companies, or school records to confirm their children’s enrollment in an institution teaching Philippine civics. Mere allegations, without competent evidence, are insufficient. Consequently, the petitioners did not satisfactorily establish their statutory qualifications, warranting the dismissal of their petition.