GR L 41399; (July, 1982) (Digest)
G.R. No. L-41399. July 20, 1982.
REPUBLIC OF THE PHILIPPINES, movant-appellee, vs. CESAR GUY, respondent-appellant.
FACTS
Cesar Guy was granted Philippine citizenship in 1959. In 1964, the Solicitor General petitioned for the cancellation of his Certificate of Naturalization on two primary grounds. First, during the pendency of his naturalization petition in 1957, Guy filed a sworn application for a timber license falsely stating he was a Filipino citizen, for which he was later convicted of perjury. Second, in 1963, he was convicted of rape with homicide, demonstrating a lack of good moral character.
Guy defended his timber license application as an act of good faith, believing his citizenship was settled after the favorable decision, and claimed he did not personally write the false statement. The case proceeded to hearing, but Guy and his counsel repeatedly failed to appear despite notices, leading the trial court to receive the Solicitor General’s evidence ex parte. Guy’s counsel filed motions and sought extensions but ultimately presented no evidence on Guy’s behalf.
ISSUE
Whether the trial court correctly ordered the cancellation of Cesar Guy’s Certificate of Naturalization.
RULING
Yes. The Supreme Court affirmed the cancellation. The legal logic rests on two independent and sufficient grounds. First, Guy’s convictions for perjury and a grave crime like rape with homicide conclusively demonstrate he lacked the “good moral character” required both at the time of naturalization and continuously thereafter. Naturalization laws demand that an applicant possesses and maintains good moral character; subsequent convictions for serious crimes provide valid grounds for denaturalization.
Second, the administration of Guy’s oath of allegiance was procedurally void. Following the precedent in Ong So v. Republic, the oath was administered prematurely—before the expiration of the 30-day period for the government to appeal the order allowing the oath. This hasty administration, done without justification, was an attempt to render the government’s right to appeal nugatory and is therefore null and void. Consequently, the certificate issued pursuant to that void oath is itself invalid. The Court also found no merit in Guy’s claim of being denied his day in court, as the record showed his counsel was given ample opportunity to present evidence but employed only delay tactics.