GR L 25438; (April, 1969) (Digest)
G.R. No. L-25438 April 25, 1969
IN THE MATTER OF THE PETITION OF WILLIAM SAY CHONG HAI, whose aliases are “WILLIAM FRANCISCO SAY”, “FRANCISCO T. SAY”, “FRANCISCO SAY y TY”, “WM. FRANCISCO SAY CHONG HAI” and “FRANCISCO WILLIAM SAY CHONG HAI” TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. WILLIAM SAY CHONG HAI, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Petitioner William Say Chong Hai filed a petition for naturalization. The lower court granted his petition on July 19, 1965. The Republic of the Philippines appealed, assigning two errors. First, the petitioner admittedly used several aliases interchangeably without judicial authority. His name appeared differently in his Birth Certificate, Alien Certificate of Registration, Immigration Certificate of Residence, Income Tax Returns, and Residence Certificates. He admitted in court to commonly using the names William Francisco Say and William Say Chiong Hai interchangeably in business and other transactions. Second, the petitioner’s character witnesses were his former professors from San Beda College. Their acquaintance with him was limited primarily to school activities and the professor-student relationship. They could not recall specific details of their conversations with him, and their knowledge dated only from 1946.
ISSUE
1. Whether the petitioner’s unauthorized use of aliases disqualifies him from naturalization for not conducting himself in a proper and irreproachable manner.
2. Whether the petitioner’s character witnesses, being his former professors with limited acquaintance, are credible persons within the meaning of the Naturalization Act.
RULING
The Supreme Court REVERSED the lower court’s decision and DENIED the petition for naturalization.
1. On the use of aliases: The unexplained and unauthorized use of an alias is fatal to an application for naturalization. It indicates that the petitioner has not conducted himself in a proper and irreproachable manner and is deemed unworthy of Philippine citizenship. The Court cited a consistent line of decisions, including Ang Tee Ye v. Republic (March 31, 1965) and Chan De v. Republic (1968), establishing this doctrine. The lower court erred in not considering this a bar.
2. On the character witnesses: The character witnesses were not credible persons as required by the Naturalization Act. A vouching witness must have known the applicant intimately and for the requisite period to act as an insurer of the applicant’s character. Knowledge limited to a school setting, where the relationship is primarily that of professor and student, is insufficient. The Court cited Lim Ching Tian v. Republic (1961) and other cases, noting that the use of tutors or professors as attesting witnesses has been consistently frowned upon because their testimony lacks the necessary depth and persuasiveness. The lower court erred in finding them competent.