G.R. No. L-14184; August 31, 1960
In the matter of the petition for admission as citizen of the Philippines. PABLO UY YAO, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Pablo Uy Yao, born on October 10, 1925, in Rosales, Pangasinan, to Chinese parents, filed a petition for naturalization. He never left the Philippines. He is married to Chua Lay, a Chinese subject, with whom he has one child. He is fluent in English and Tagalog and knows several Philippine dialects. He completed his elementary, secondary, and collegiate education (Bachelor of Science in Civil Engineering from Far Eastern University) in Philippine schools recognized by the government. After graduation, he worked for Atkins, Kroll and Co., Inc., and later for La Perla Cigar and Cigarette Factory. He believes in the principles of the Philippine Constitution, has conducted himself properly, and has mingled socially with Filipinos. Being born in the Philippines and educated in local schools, he was exempt from filing a declaration of intention. The Court of First Instance of Manila granted his petition. The Republic appealed, contending that the supporting affidavits of his two character witnesses were deficient for failing to state that the affiants knew the petitioner to be a resident of the Philippines for the period required by law.

ISSUE

Whether the petition for naturalization should be denied due to deficiencies in the supporting affidavits of the character witnesses, specifically the omission of a statement regarding the petitioner’s period of residence in the Philippines.

RULING

The Supreme Court affirmed the lower court’s decision granting citizenship. The Court held that while the original supporting affidavits did not contain the specific statement about knowing the petitioner’s residency period as required by Section 7 of the Revised Naturalization Law, this deficiency was cured. Both witnesses testified at the hearing that they were townmates of the petitioner and personally knew him to be a resident of the Philippines for more than the required period (18 and 30 years, respectively). They also executed amended affidavits to rectify the omission. The Court ruled that this amendment did not necessitate a republication of the notice of the petition, as the amendment did not alter the form or substance of the already-published notice, which is only required to contain the petitioner’s name, birthplace, residence, arrival details, witnesses’ names, and hearing date. The purpose of publication—to inform the public and officers—was not defeated. Furthermore, the Court rejected the Solicitor-General’s contention that the affidavits must also detail the petitioner’s belief in Philippine principles, social mingling, and desire to embrace Filipino customs, as the law does not require such specifics in the affidavits. The evidence justified the finding that petitioner possessed all qualifications and none of the disqualifications for citizenship.