G.R. No. L-18885; January 31, 1964
CHIENG YEN, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

Petitioner Chieng Yen, a Chinese citizen, filed a petition for naturalization with the Court of First Instance of Manila on September 16, 1958. He claimed to have transferred his residence from Olongapo, Zambales, to Manila in February 1955. To support this, he presented testimonial evidence from witnesses who attested to helping him move his belongings to Manila and conducting business with him there. He also submitted a Bureau of Immigration certificate, issued in March 1959, advising of his change of address effective February 1955.
The lower court denied the petition, finding it lacked jurisdiction because petitioner was not a resident of Manila for the required one year preceding his petition. The court based this on official documents executed by petitioner himself, which contradicted his claim of Manila residence. These documents included his sworn declaration of intention to become a citizen filed in July 1957, his income tax return for 1957 filed in February 1958, and his alien registration records, all consistently stating his residence as Olongapo, Zambales.

ISSUE

Whether the Court of First Instance of Manila validly acquired jurisdiction over the naturalization petition, which hinges on whether petitioner was a bona fide resident of Manila for at least one year immediately preceding the filing of his petition.

RULING

The Supreme Court affirmed the lower court’s decision, ruling that it correctly dismissed the petition for lack of jurisdiction. The legal logic centers on the statutory requirement of one-year residence in the locality where the petition is filed and the substantive definition of “residence” for jurisdictional purposes. The Court held that legal residence, or domicile, requires not only an intention to reside in a fixed place but also actual personal presence coupled with conduct indicative of that intention.
Petitioner’s evidence of Manila residence was deemed insufficient and unreliable when weighed against his own sworn official declarations. The documentary evidence he submitted was fatally flawed; the Immigration certificate advising of the address change was issued only in March 1959, nearly four years after the alleged 1955 transfer and six months after filing the petition, rendering it suspect. In contrast, his repeated sworn statements in his declaration of intention, tax return, and alien reports—all identifying Olongapo as his residence—were given more credence as they were contemporaneous and reflected his official standing. The Court noted that all his business interests, which were his main income source, were in Olongapo, and it took judicial notice that Chinese businessmen typically reside where their businesses are located. His failure to even list all former residences in his petition was an additional disqualifying factor. Consequently, the petitioner failed to prove the requisite one-year Manila residence, depriving the court of jurisdiction.