G.R. No. L-10286; May 23, 1958
LUIS F. ARRIOLA, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Luis F. Arriola, born in Manila on August 19, 1926, of Chinese parents, filed a petition for naturalization. He had resided in the Philippines for the required period, was single, a college graduate, employed as manager of his father’s cafeteria with an income, had savings, spoke English and Tagalog, and had two Filipino character witnesses who attested to his good moral character and law-abiding conduct. He was dispensed from filing a declaration of intention due to his birth in the country. During the hearing, upon cross-examination, he presented his 1955 residence certificate (Exhibit 1), which erroneously stated his citizenship as “Filipino” instead of “Chinese.” Arriola explained he acquired the certificate through an agent and only noticed the error then. At the next hearing, he presented the same certificate, which on its reverse side bore a correction to “Chinese” with an explanation and the initials of Rufino Cervantes, Chief of the Residence Certificate Section of the Manila City Treasurer’s Office, who testified he made the change. The Solicitor General opposed the petition, arguing this incident demonstrated Arriola lacked the requisite good moral character and irreproachable conduct. The lower court granted the petition, and the Government appealed.

ISSUE

Whether Luis F. Arriola has proven he is of good moral character and has conducted himself in a proper and irreproachable manner during his residence in the Philippines, as required for naturalization, in light of the erroneous entry in his residence certificate and his subsequent act of having it corrected.

RULING

The Supreme Court AFFIRMED the lower court’s decision granting the petition for naturalization. The Court held that Arriola’s act of causing the correction of the erroneous citizenship entry in his residence certificate, which he had procured through an agent and did not initially notice, did not reflect unfavorably on his moral character or conduct. The correction was made by the official (Cervantes) having custody of the record to make the document speak the truth. Citing U.S. v. Mateo (25 Phil. 324), the Court ruled that an alteration which makes a document truthful, and is not capable of producing fraud or obtaining an undeserved privilege, cannot be a basis for impugning one’s character. Therefore, Arriola satisfied the statutory requirement of good moral character and irreproachable conduct.