G.R. No. L-15027. January 31, 1964.
IN THE MATTER OF THE PETITION OF JIMMY LEE TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. JIMMY LEE, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Jimmy Lee, a Chinese national, filed a petition for naturalization with the Court of First Instance of Iloilo on November 17, 1956. He attached a copy of his declaration of intention, the original of which he had sent by registered mail to the Office of the Solicitor General on October 23, 1953. After trial, the court rendered judgment on August 15, 1958, admitting him to Philippine citizenship. This judgment became final as the Solicitor General’s appeal was filed out of time.
Subsequently, the Solicitor General discovered that while Lee’s declaration of intention was mailed in 1953, the mandatory filing fee of P10.00 was only paid on May 23, 1956, upon demand. Consequently, the Solicitor General filed a motion to annul the proceedings, arguing that the declaration was validly filed only upon payment of the fee, which was less than one year before the petition was filed, violating the jurisdictional requirement.

ISSUE

Whether the petitioner’s declaration of intention was validly filed on the date it was mailed in 1953 or only on the date the filing fee was paid in 1956, for purposes of complying with the one-year requirement prior to filing a naturalization petition.

RULING

The Supreme Court ruled in favor of the Republic, annulling the naturalization proceedings. The legal logic is anchored on strict compliance with statutory and regulatory requirements for naturalization, which are jurisdictional. Section 5 of the Naturalization Law requires the filing of a declaration of intention at least one year before the petition. Pursuant to Section 21 of the same law, the Secretary of Justice issued regulations, one of which mandates the payment of a P10.00 filing fee upon filing the declaration.
The Court applied the principle that payment of the prescribed fee is an essential part of the filing process. Citing the analogous precedent in Lazaro vs. Endencia (57 Phil. 552) concerning appellate docket fees, the Court held that a legal step requiring a fee is not perfected until the fee is fully paid. Therefore, Lee’s act of mailing the declaration in 1953 without simultaneous payment of the fee produced no legal effect. The declaration was deemed filed only on May 23, 1956, when the fee was paid. Since his petition for naturalization was filed on November 17, 1956, the intervening period was only about five and a half months, not the required one year. This fatal defect deprived the trial court of jurisdiction. Consequently, the order denying the motion to annul was reversed, and all proceedings below were declared null and void.