G.R. No. L-37100 September 19, 1980
WEE BIN, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

In 1937, Wee Bin was granted Philippine citizenship by the Court of First Instance of Zamboanga City, which issued Certificate of Naturalization No. 57. During World War II, both the court records and his physical certificate were destroyed or lost. In 1951, Wee Bin filed a petition for restoration of the record under Rule 124. The court, after a hearing where Wee Bin presented evidence including affidavits and witness testimony, granted the petition in an order dated May 9, 1951. The Republic, represented by the City Attorney who cross-examined a witness but presented no opposing evidence, did not appeal. A new Certificate of Naturalization No. 6 was subsequently issued.
Nearly two decades later, in 1970, the Republic, through the Solicitor General, filed a motion to set aside the 1951 restoration order and cancel the certificate. The Republic argued the proceedings were void for lack of publication, absence of an authentic document base, and reliance on false evidence. The trial court denied the motion, ruling it was a belated collateral attack on a final order and that the presented evidence aimed to assail the original 1937 naturalization, which was irrelevant to the motion challenging the restoration proceeding.

ISSUE

Whether the trial court erred in denying the Republic’s motion to set aside the 1951 restoration order and cancel the certificate of naturalization.

RULING

The Supreme Court affirmed the denial. The 1951 restoration order had long become final and executory, the Republic having received a copy and not appealed. The motion filed in 1970 constituted an impermissible collateral attack on that final order. On the merits, the Court found the 1951 restoration proceeding was valid. The Republic actively participated through cross-examination but offered no counter-evidence, and the trial court correctly found sufficient proof of the pre-war naturalization grant based on the presented evidence, including witness testimony and an affidavit Wee Bin filed with a bank in 1944 to assert his citizenship. The Court also upheld the trial court’s disallowance of evidence attacking the validity of the original 1937 naturalization, as the motion only assailed the 1951 restoration order. A separate denaturalization proceeding would be the proper remedy for challenging the underlying citizenship grant, not a motion to set aside the restoration. The appeal was dismissed for lack of merit.