GR L 32287; (February, 1974) (Digest)
G.R. No. L-32287 February 28, 1974
IN THE MATTER OF THE PETITION OF JUANITO SY TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. JUANITO SY, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Petitioner Juanito Sy filed a petition for naturalization on February 17, 1961. The petition, however, did not expressly state that he was of good moral character as required by Section 7 of Commonwealth Act No. 473 . After a hearing, the Court of First Instance of Manila rendered a decision on December 11, 1961, granting the petition subject to compliance with Republic Act No. 530 . The Solicitor General appealed. Years later, on October 23, 1965, the lower court issued an order finding that Sy had complied with the requirements for oath-taking, noting his increased income. The Republic appealed this order, arguing multiple substantive and procedural defects in the petition.
ISSUE
The primary issue is whether Juanito Sy validly complied with all legal requirements for naturalization, warranting the grant of Philippine citizenship.
RULING
The Supreme Court reversed the lower court’s decision and order, denying the petition for naturalization. The Court’s legal logic is anchored on the principle that naturalization is a privilege of the highest public interest, requiring strict and complete compliance with statutory mandates. The Court scrutinized the entire record and found fatal jurisdictional and substantive flaws. First, Sy’s petition failed to contain an express averment that he was of good moral character, a mandatory and jurisdictional requirement under the law. This omission alone is sufficient to void the proceedings. Second, Sy’s income at the time of filing his petition in 1961 was only P3,000 annually, which the Court deemed not lucrative, disqualifying him under the qualification of having a lucrative trade or profession. An increase in income subsequent to the filing cannot cure this initial deficiency. Third, Sy failed to submit a duly authenticated copy of his intention to renounce Chinese nationality from the Ministry of Interior of the Republic of China by the time of the 1965 order. The Court also noted that the published notice of hearing did not restate the petition verbatim but merely summarized it, which is a procedural infirmity. Given these cumulative defects, Sy failed to discharge the heavy burden of proving full compliance with the Naturalization Law. The appeal by the Republic was thus sustained.