G.R. No. L-20305 March 31, 1965
IN THE MATTER OF THE PETITION OF ANG TEE YEE TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. ANG TEE YEE, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

On December 27, 1960, Ang Tee Yee filed a petition for naturalization with the Court of First Instance of Manila. The petition and the scheduled hearing were published in the Daily Mirror and the Official Gazette for three consecutive weeks. After a hearing, the trial court granted the petition. The Republic of the Philippines appealed, raising six errors. The records revealed that the petitioner had been known by another name, “Lim Tee Yee,” as indicated in his Alien Registration Certificate and designated as an alias in his clearance. This other name was not included in the publication of his application. It was not shown that he was authorized to use such an alias.

ISSUE

Whether the trial court validly acquired jurisdiction over the naturalization petition given the petitioner’s unexplained and unauthorized use of an alias and the failure to include that alias in the publication of the application.

RULING

The Supreme Court reversed the decision of the trial court and denied the petition for citizenship. The Court ruled that the unexplained and unauthorized use of an alias is sufficient to deny a petition for naturalization. Furthermore, because the petitioner used another name (“Lim Tee Yee”) which appeared in his official documents, that name should have been included in the publication of his application. The failure to do so rendered the publication insufficient, as people who knew him by that alias were not properly informed of his application and could not come forward with relevant information. Consequently, the trial court did not validly acquire jurisdiction over the case. In view of this jurisdictional defect, the Court deemed it unnecessary to discuss the other issues raised on appeal.