G.R. No. 202809 , July 2, 2014
DENNIS L. GO, Petitioner, vs. REPUBLIC OF THE PHILIPPINES, Respondent.

FACTS

Dennis L. Go, a Chinese national born in Manila on May 7, 1982, filed a petition for naturalization under Commonwealth Act No. 473 (the Revised Naturalization Law) with the Regional Trial Court (RTC) of Manila. He alleged he possessed all qualifications and none of the disqualifications under the law, including being of legal age, good moral character, belief in Philippine constitutional principles, and continuous residence in the Philippines. He claimed exemption from filing a Declaration of Intention as he was born and educated in the Philippines. After compliance with publication and posting requirements, hearings were conducted where Go testified and presented witnesses: Dr. Joseph Anlacan (psychiatrist), Dr. Edward C. Tordesillas (medical examiner), Silvino J. Ong (family friend/neighbor), Teresita M. Go (aunt), and Juan C. Go (affiant of support). The Office of the Solicitor General (OSG) initially posed no objection to Go’s evidence but later moved to reopen trial to submit an NBI report suggesting non-compliance. Go countered with his own NBI clearance. The RTC admitted evidence from both parties but denied the motion to reopen. The RTC granted the petition, finding Go possessed all legal qualifications. The OSG moved for reconsideration, seeking to admit a Bureau of Immigration background investigation report citing reasons like his parents’ Chinese citizenship and alleged family business issues. The RTC denied this motion. On appeal, the Court of Appeals (CA) reversed the RTC, dismissing the petition without prejudice. The CA found that while Go’s language ability could be inferred, he failed to prove his character witnesses were credible as required by law—specifically, that they were persons of good standing in the community known to be honest, upright, trustworthy, and reliable. Go elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in reversing the Regional Trial Court’s grant of naturalization, specifically on the ground that petitioner Dennis L. Go failed to adduce sufficient evidence to prove the credibility of his character witnesses as required under Section 7 of Commonwealth Act No. 473 .

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ decision. The ruling held that an applicant for naturalization must prove strict compliance with all statutory requirements, and citizenship is a privilege that should not be lightly conferred. The Court emphasized that under Section 7 of C.A. No. 473 , a petition must be supported by affidavits of at least two credible persons who are Philippine citizens, personally know the petitioner, and can vouch for the petitioner’s residency, good repute, moral character, qualifications, and lack of disqualifications. Citing precedent (e.g., Republic v. Agas), the Court ruled that “credible persons” means those with good standing in the community, known to be honest and upright, reputed to be trustworthy and reliable, and whose word can be taken as a good warranty of the applicant’s worthiness. The Court found that petitioner Go failed to present evidence establishing the credibility and good standing of his witnesses in the community. The testimonies and affidavits merely stated the witnesses knew Go and considered him of good moral character but did not demonstrate their own status as credible persons as defined by law. The Court reiterated that the qualifications of the witnesses themselves are indispensable facts that must be proven, and failure to do so is fatal to the petition. Therefore, the CA correctly reversed the RTC’s grant of naturalization.