G.R. No. L-23515; February 27, 1969
IN THE MATTER OF THE PETITION OF CHOA HAI TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. CHOA HAI, petitioner-appellant, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellee.

FACTS

Petitioner Choa Hai was granted admission to Philippine citizenship by the Court of First Instance of Batangas on October 12, 1961. On October 17, 1963, he filed a motion to take his oath and be issued a certificate of naturalization. The Provincial Fiscal opposed the motion on several grounds: (1) petitioner failed to state his former places of residence in his petition; (2) his two character witnesses were not qualified to vouch for his moral character; (3) he made misrepresentations in reporting his 1962 income for tax purposes; and (4) he was using an alias without proper authority. On June 11, 1964, the court set aside its 1961 decision and denied the motion to take oath. Petitioner appealed.
During the hearing, it was established that from December 1921 to 1927, petitioner resided in Manila, not Batangas, though his petition stated he had been a resident of Batangas since December 1921. He claimed that from 1921 to 1927, as a minor, he was under the custody of Vicente Chua, who had a store in Manila but a residence in Batangas which they visited frequently. The court found no proof of this guardianship other than petitioner’s testimony.
Furthermore, the character witnesses, Juan C. Perez and Aniceto Sison, who knew petitioner since 1930 and 1927 respectively, were deemed not qualified as their personal knowledge did not cover the entire duration of his residence. The publication of the petition in the “Nueva Era” newspaper was also defective, as there was no proof it was of general circulation in Batangas. Additionally, three of petitioner’s eight children were enrolled in schools presumed to be run by Chinese nationals, which was contrary to the requirement of embracing Filipino customs.
Most seriously, in his reply brief, petitioner’s counsel submitted Annexes A, B, C, and D, which the Solicitor General alleged were forged documents. The Court required petitioner to produce the originals and show cause why he should not be cited for contempt. Petitioner’s counsel did not refute the forgery charge, only disclaiming authorship. A Court Investigator found the documents to be forgeries, obtained by petitioner for a consideration from a man posing as a lawyer from the Department of Justice.

ISSUE

Whether the lower court correctly denied petitioner Choa Hai’s motion to take his oath and be issued a certificate of naturalization, thereby declaring him not qualified for Philippine citizenship.

RULING

Yes, the lower court’s order is affirmed. Petitioner is declared not qualified to be admitted as a citizen of the Philippines.
The Supreme Court sustained the lower court on multiple grounds. First, petitioner violated Section 7 of the Revised Naturalization Law by failing to state his actual residence in Manila from 1921 to 1927 in his petition. The requirement refers to all places of actual residence, not just legal domicile, and this omission is fatal regardless of good faith.
Second, his character witnesses were not qualified, as they did not know him for the entire period of his residence.
Third, the publication of the petition was defective for lack of proof that the newspaper was of general circulation in Batangas.
Fourth, the enrollment of his children in schools run by Chinese nationals indicated a lack of sincere desire to embrace Filipino customs.
Most decisively, petitioner’s submission of forged documents in his reply brief demonstrated a lack of the required good moral character and irreproachable conduct. His behavior in paying for false certifications made him unworthy of Philippine citizenship. The Court also warned attorneys to scrutinize documents submitted by clients to avoid presenting forgeries.