G.R. No. L-11384, December 26, 1958
In the matter of the petition of Jose Go to be admitted a citizen of the Philippines. JOSE GO, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

This is an appeal from a decision of the Court of First Instance of Davao in a naturalization proceeding for Jose Go. The trial court found that Jose Go proved he possessed all the necessary qualifications for naturalization. However, instead of merely approving his application, the trial court’s decision expressly declared him to be a Filipino citizen by naturalization and ordered the clerk of court to issue the corresponding certificate of citizenship after the lapse of two years from the date the decision becomes final and executory.

ISSUE

Whether the trial court’s decision, which immediately declared the petitioner a Filipino citizen by naturalization, is erroneous under the applicable law.

RULING

Yes, the trial court’s decision is erroneous. The Supreme Court found the contention of the Solicitor General to be well-founded. Under Republic Act No. 530 , a judgment granting citizenship becomes executory only after two years from its promulgation, and only after a hearing where the applicant proves he has complied with additional requirements during that period (such as not leaving the Philippines, continuously engaging in a lawful profession, and having no convictions or acts prejudicial to the nation). The trial court’s decision was therefore modified. The Supreme Court approved the petition for naturalization of Jose Go, correcting the lower court’s error of immediately declaring him a citizen. The Court also noted the duty of a party to call the attention of the trial judge to evident mistakes to avoid unnecessary appeals.