GR L 15955; (October,1961) (Digest)
G.R. No. L-15955; October 26, 1961
IN RE: PETITION FOR NATURALIZATION, NARCISO CHING, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Narciso Ching filed a petition for naturalization in the Court of First Instance of Rizal. The court granted his petition, finding him to possess the qualifications required under Commonwealth Act No. 473, the Revised Naturalization Law. The Republic of the Philippines, through the Solicitor General, appealed the decision.
The oppositor-appellant contended that the petitioner failed to comply with two essential statutory requirements. First, it was argued that Ching’s petition did not contain, and he did not present evidence to prove, a declaration of his belief in the principles underlying the Philippine Constitution. Second, the Republic asserted that he failed to allege and prove his continuous residence in the Philippines from the date of filing the petition up to the time of his admission to citizenship.
ISSUE
The core issue is whether the lower court erred in granting the petition for naturalization despite the petitioner’s failure to allege and prove his belief in the principles underlying the Philippine Constitution, as mandatorily required by the Revised Naturalization Law.
RULING
The Supreme Court reversed the decision of the lower court and denied the petition for naturalization. The legal logic is anchored on strict compliance with the explicit statutory prerequisites for naturalization.
Commonwealth Act No. 473, Section 2, explicitly requires an applicant to be one who “believes in the principles underlying the Philippine Constitution.” Furthermore, Section 7 mandates that the petition must contain a declaration of the applicant’s qualifications. The official form for such a petition, prescribed under the law, includes a specific averment: “I believe in the principles underlying the Philippine Constitution.”
The Court found that Narciso Ching’s printed petition, as part of the Record on Appeal, conspicuously lacked this required assertion. This fatal omission was not cured by the proceedings at the hearing. While his counsel argued that the petitioner had stated his belief in the ideals of the Filipino people during the hearing, the Court held this to be insufficient. The requirement is specific and categorical; it demands an explicit declaration of belief in the principles of the Constitution itself, not merely in general national ideals. The Court emphasized that one seeking Philippine citizenship must expressly declare allegiance to the Constitution and its principles, and may even be examined on what those fundamental principles are.
Since the petitioner failed to allege this essential qualification in his petition and to present competent proof thereof during trial, the lower court had no legal basis to grant citizenship. This failure alone warranted the denial of the petition. Consequently, the Supreme Court found it unnecessary to resolve the appellant’s second objection regarding continuous residence. The decision was reversed.