GR L 15794; (December, 1962) (Digest)
G.R. No. L-15794. December 29, 1962. CHIN GUAN GO, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, opponent-appellant.
FACTS
Petitioner Chin Guan Go filed his application for naturalization with the Court of First Instance of Sulu on July 1, 1958. He alleged continuous residence in the Philippines since birth, specifically in the Walled City, Jolo, Sulu. The evidence, however, revealed that after graduating from Sulu High School in 1948, he moved to Manila to work as a salesman at Young’s Hardware Store. He married a Filipino from Jolo in 1953, but the couple lived in Manila where their three children were born. He filed income taxes in Manila, and his family only vacationed in Jolo during December and May each year.
The State appealed the trial court’s grant of the naturalization petition, contending the court lacked jurisdiction. The State argued that Go had not been a resident of the province of Sulu for at least one year immediately preceding the filing of his petition, as mandatorily required by Section 8 of Commonwealth Act No. 473 , as amended.
ISSUE
Whether the Court of First Instance of Sulu had jurisdiction to hear and determine the naturalization petition, given the requirement of one-year provincial residence immediately preceding its filing.
RULING
The Supreme Court reversed the trial court’s decree and dismissed the petition. The legal logic centers on the jurisdictional nature of the one-year provincial residence requirement under Section 8 of the Naturalization Law. Jurisdiction is conferred solely upon the Court of First Instance of the province where the petitioner has resided for at least one year immediately before filing. This requirement is not merely procedural or waivable; it is a substantive condition precedent to the court’s authority to act.
The Court meticulously examined the evidence, which “indubitably” showed Go was not a resident of Jolo, Sulu, for the required period. His principal domicile and center of life were in Manila, where he was continuously employed, filed taxes, and raised his family from 1948 onward. His occasional vacations to Jolo did not constitute the legal residence required by the statute. The purpose of the rule is to enable the local court to effectively verify the applicant’s background, character, and conduct, which is impractical if he resides elsewhere. The State’s failure to raise this specific objection during the trial did not constitute a waiver, as jurisdictional defects in naturalization cases can be questioned at any stage. Consequently, the Sulu court never acquired jurisdiction, rendering its decree void. The dismissal was without prejudice to Go filing a new petition in the proper court.