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IN THE MATTER OF THE PETITION OF LEE PA TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. TAN LIN, ET AL., petitioners-appellants, vs. THE REPUBLIC OF THE PHILIPPINES, oppositor-appellee.
FACTS
Lee Pa filed a petition for naturalization, which was granted by the Court of First Instance of Manila on March 31, 1953. Pursuant to Republic Act No. 530, the decision did not become executory until after a two-year period, which lapsed on March 31, 1955. Lee Pa did not take the oath of allegiance during this period and died on September 26, 1956. His heirs, widow Tan Lin and their nine minor children, filed a petition on March 6, 1958, to continue the proceedings under Section 16 of the Revised Naturalization Law (Commonwealth Act No. 473). They prayed that Lee Pa be declared a naturalized citizen, that Tan Lin be allowed to take the oath of allegiance, and that they be granted the rights of citizens under Section 15 of the same Act.
The Solicitor General opposed, arguing that Section 16 applies only if the petitioner dies before a final decision, that Lee Pa showed disinterest by not taking the oath, and that the oath is a personal act that cannot be performed by another. The lower court denied the petition, relying on these grounds and citing the case of Chua Chian v. Concepcion.
ISSUE
Whether the widow and minor children of a deceased naturalization petitioner, who died after the favorable decision became final but before he could take the oath of allegiance, can continue the proceedings under Section 16 of the Revised Naturalization Law.
RULING
Yes. The Supreme Court reversed the lower court’s order and remanded the case for further proceedings. The legal logic centers on the interpretation of Section 16 in relation to Republic Act No. 530. While Section 16 literally allows continuation only if death occurs “before the final decision has been rendered,” the Court reasoned that this provision was enacted before R.A. No. 530 introduced the two-year waiting period before a decision becomes executory. Thus, a strict literal interpretation would be inequitable, as it would exclude cases where death occurs during this new statutory interregnum between a final judgment and its execution. The Court held that a judgment in naturalization does not become final in the strict sense until after compliance with R.A. No. 530’s requirements, including the taking of the oath.
Furthermore, the Court distinguished the case from Chua Chian. Here, Tan Lin did not seek to take the oath on behalf of her deceased husband-an impossible act-but sought to take it on her own behalf to derive citizenship through her husband’s naturalization under Section 15, provided she herself was lawfully naturalizable. The negligence in not promptly pursuing the oath after the two-year period was excused due to Lee Pa’s illness and subsequent death, and the widow’s pressing responsibilities. The qualifications under review remained those of the original petitioner, Lee Pa, and the continuation of the proceedings was therefore permissible to give effect to the legislative intent of benefiting the immediate family.
