GR 227600; (May, 2022) (Digest)
G.R. No. 227600 , June 13, 2022
HO CHING YI, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, RESPONDENT.
FACTS
Petitioner Ho Ching Yi, a Taiwanese citizen, filed a petition for naturalization on September 17, 2010. She alleged continuous residence in the Philippines since 1994, employment as treasurer of Tungtay Trading and Manufacturing Corporation since 2009, and an average annual income of ₱240,000.00. In support of her petition, she attached affidavits from her former tutors, Mary Ann R. Tamondong and Maritess S. Adaon, and presented them as witnesses. The Regional Trial Court denied her petition, finding insufficient evidence to prove her qualifications. The trial court doubted the credentials of her witnesses and their capacity to testify on her character, noting that a tutor-tutee relationship was insufficient. It also found inconsistencies regarding her claimed average annual income, which undermined her claim of good moral character. The Court of Appeals affirmed the trial court’s decision. Ho Ching Yi filed a Petition for Review on Certiorari, arguing that her witnesses were credible and explaining that her income declined due to Typhoon Ondoy and a change in employment.
ISSUE
Whether or not the Court of Appeals erred in finding that petitioner Ho Ching Yi’s witnesses were not credible to support her petition for naturalization.
RULING
The Petition is denied. The Supreme Court affirmed the decisions of the lower courts. The burden of proving strict and complete compliance with naturalization requirements rests solely on the applicant, and naturalization laws are strictly construed in favor of the government. Commonwealth Act No. 473 requires that a petition be supported by the affidavits of at least two “credible persons” who can vouch for the applicant’s good moral character and qualifications. The Court, citing Republic v. Hong, emphasized that a “credible person” under the law must have a good standing in the community, be known as honest and upright, and be reputed as trustworthy and reliable. Petitioner failed to present evidence to establish that her witnesses, her former tutors, possessed this high degree of reputation in the community. Their affidavits and testimonies alone were insufficient to prove their credibility as required by law. Furthermore, the unexplained inconsistencies regarding her income further weakened her petition. Therefore, petitioner failed to discharge her burden of proof.