GR L 33027; (April, 1974) (Digest)
G.R. No. L-33027. April 26, 1974.
IN THE MATTER OF THE PETITION TO BE ADMITTED A CITIZEN OF THE PHILIPPINES. BENJAMIN NG, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.
FACTS
Benjamin Ng filed a petition for naturalization. The Republic opposed, arguing he failed to conduct himself in a proper and irreproachable manner, specifically by registering his daughter Jennifer’s birth with the Bureau of Immigration beyond the period required by the Alien Registration Act of 1950 and by failing to file a required statement of assets under the Tax Census Law ( R.A. No. 2070 ). Ng explained the late registration was an unintentional minor lapse due to the child’s birth consuming his attention, and the non-filing was due to an honest belief it was unnecessary as he had no significant assets or income.
The lower court granted the petition, finding no ill intent. It noted the child was eventually registered upon payment of a nominal fine and that Ng later complied with tax census requirements. The court also rejected other grounds concerning social mingling and the qualifications of character witnesses. The Republic appealed, contending the legal violations constituted a disqualifying failure to maintain proper and irreproachable conduct.
ISSUE
Whether Benjamin Ng’s late registration of his child’s birth under the Alien Registration Act constitutes a failure to conduct himself in a proper and irreproachable manner, disqualifying him from naturalization.
RULING
The Supreme Court reversed the lower court’s decision and denied the petition for naturalization. The legal logic is anchored on the strict requirement that an applicant must have conducted himself in a proper and irreproachable manner throughout his residence. The Court, citing the controlling precedent in Lai v. Republic, held that a late registration of a child’s birth is not a mere minor infraction but a substantive violation of the Alien Registration Act. The law mandates timely registration, and tardy compliance demonstrates a disregard for legal duties.
The Court rejected Ng’s explanations. His claim of preoccupation with the child’s birth does not excuse the legal obligation, and his subjective belief about the tax requirement does not negate the violation. The ruling in Lai established that such violations constitute improper and irreproachable conduct in relations with the government, which is an incurable disqualification for naturalization. Since this ground alone is sufficient to bar the petition, the Court deemed it unnecessary to address the Republic’s other objections regarding social mingling and character witnesses. The decision underscores that strict compliance with Philippine laws is a non-negotiable prerequisite for conferring citizenship.