G.R. No. L-19419. September 30, 1964.
IN THE MATTER OF THE PETITION OF GAW CHING TO BE ADMITTED A CITIZEN OF THE PHILIPPINES, GAW CHING, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

The petitioner-appellee, Gaw Ching, filed an application for naturalization before the Court of First Instance of Manila, which was granted. The Republic of the Philippines, through the Solicitor General, appealed the decision, assigning three principal errors. The oppositor-appellant argued that the petitioner failed to comply with Section 7 of the Revised Naturalization Law ( Commonwealth Act No. 473 , as amended) by not stating his former places of residence in his petition. The petitioner admitted this omission but claimed it was due to inadvertence, arguing that his former residence at No. 512 Asuncion Street was nearby his current residence at No. 699 of the same street, thus not materially affecting the requisite investigation.
Furthermore, the Republic contended that the petitioner’s character witnesses, Salvador Estenzo and Benjamin Amog, were not “credible persons” as required by law and failed to adequately establish the petitioner’s qualifications and lack of disqualifications. The Solicitor General also filed a motion to remand the case for new evidence allegedly showing bad faith or misrepresentation by the petitioner, but the Court deferred action on this motion pending the appeal.

ISSUE

Whether the Court of First Instance erred in granting Gaw Ching’s petition for naturalization despite non-compliance with statutory requirements and insufficient evidence from character witnesses.

RULING

The Supreme Court reversed the decision of the lower court and denied the petition for naturalization. On the first issue, the Court held that the petitioner’s failure to state his former places of residence in his application, as mandatorily required by Section 7 of the Revised Naturalization Law, was a fatal defect. The Court rejected the petitioner’s argument that the proximity of his old and new addresses rendered the omission inconsequential. It emphasized that in a densely populated area like Manila, even a short distance could significantly impact the effectiveness of the background investigation conducted by authorities. The omission is presumed to impair the investigation’s substantial efficacy unless proven otherwise, and no such proof was offered by the petitioner.
On the second issue, the Court found the petitioner’s character witnesses inadequate. Citing jurisprudence, the Court defined a “credible person” under the law as one of good standing in the community, honest, upright, trustworthy, and reliable, whose word acts as a warranty of the applicant’s worthiness. The records failed to show that witnesses Estenzo and Amog, particularly the latter, met this standard. Their testimony was too general and did not demonstrate sufficient knowledge of the petitioner to attest credibly to his qualifications and absence of disqualifications. The Court noted an inconsistency in Amog’s testimony regarding the petitioner’s residence, further undermining his credibility. Given these dispositive grounds, the Court deemed it unnecessary to rule on the third assignment of error regarding the petitioner’s lucrative occupation or on the motion to remand for new evidence. The petition was denied, with costs against the petitioner-appellee.