G.R. No. 220674 , December 02, 2021
SEFYAN ABDELHAKIM MOHAMED A.K.A. SEFYAN ABDELHAKIM MOHAMED HUSSIN, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.

FACTS

Sefyan Abdelhakim Mohamed, a Sudanese national married to a Filipino citizen, applied for Philippine citizenship. He filed a Declaration of Intention on June 2, 2006, and a Supplemental Declaration of Intention on July 20, 2007. On August 21, 2007, he filed his Petition for Naturalization before the Regional Trial Court (RTC) of Pasay City. The RTC granted his petition on October 7, 2009. Subsequently, Mohamed moved to take his oath of allegiance, which the RTC allowed in an Order dated September 24, 2012. He took his oath on October 24, 2012. The Republic, through the Office of the Solicitor General (OSG), appealed, arguing that Mohamed filed his petition less than one year after his Supplemental Declaration of Intention, failed to substantiate his qualifications with competent evidence (such as a medical certificate to prove he was not suffering from any mental alienation or incurable contagious disease), and that his oath was void because it was administered before the expiration of the Government’s period to appeal. The Court of Appeals reversed the RTC, dismissed the petition for naturalization without prejudice, and declared his oath and any certificate of naturalization void.

ISSUE

Whether the Court of Appeals correctly dismissed Mohamed’s petition for naturalization on the grounds of: (1) non-compliance with the mandatory one-year period between the filing of a declaration of intention and the petition for naturalization; (2) insufficiency of evidence to prove his qualifications, particularly the lack of a medical certificate; and (3) the nullity of his prematurely administered oath of allegiance.

RULING

Yes, the Court of Appeals’ dismissal was correct. The Supreme Court affirmed the denial of the petition for naturalization.
1. Non-compliance with the One-Year Period: The filing of a Declaration of Intention one year prior to the petition for naturalization is a mandatory jurisdictional requirement under Commonwealth Act No. 473 (The Revised Naturalization Law). The Court held that this period must be reckoned from the filing of the Supplemental Declaration of Intention, as it superseded the original. Since Mohamed filed his petition on August 21, 2007, less than one year after his Supplemental Declaration was received on July 20, 2007, he failed to comply with this indispensable requirement, rendering the proceedings void.
2. Insufficiency of Evidence: The applicant bears the burden of proving strict compliance with all legal requirements. Mohamed failed to present competent evidence, such as a medical certificate, to prove he was not suffering from any mental alienation or incurable contagious disease, as required by law. The general testimonies of his witnesses on this point were deemed insufficient. Naturalization laws are strictly construed in favor of the State, and the absence of one jurisdictional requirement warrants denial.
3. Nullity of the Oath: The oath of allegiance was administered on October 24, 2012, before the OSG’s period to appeal the RTC’s Order allowing the oath (which it received on October 17, 2012) had expired on November 16, 2012. This premature administration was a nullity, as it attempted to render the government’s right to appeal nugatory.
The Court rejected Mohamed’s invocation of the 1951 Convention relating to the Status of Refugees and the case of Republic v. Karbasi, noting that compliance with the procedural and substantive requirements of Philippine naturalization law remains paramount. The privilege of naturalization is a statutory grace, not a right, and requires full and complete compliance with the law.