G.R. No. L-4566; January 24, 1955
Republic of the Philippines, petitioner-appellant, vs. Jacob Joseph Assad, respondent-appellee.

FACTS

Jacob Joseph Assad applied for naturalization on April 11, 1949. The Court of First Instance of Rizal granted his application on October 12, 1949. After the decision became final, Assad took his oath of allegiance and was issued a certificate of naturalization on December 28, 1949. On May 4, 1950, the Solicitor General moved for the cancellation of the certificate, alleging it was secured illegally and fraudulently. The motion specified several acts of misrepresentation and misconduct: (a) In September 1946, Assad allegedly threatened Blandina Gamboa Hilado with a gun to prevent enforcement of a Supreme Court writ; (b) In February 1948, Assad and others allegedly attacked and injured Lourdes Hilado; (c) Prior to naturalization, Assad misrepresented himself as Salim Jacob Assad, a naturalized Filipino, to purchase real properties; (d) These acts were the subject of a deportation case suspended at Assad’s request; (e) In Civil Case No. 70075, Assad allegedly gave false testimony about Salim Jacob Assad’s income; (f) In his naturalization hearing, Assad falsely testified that all cases against him had been dismissed when the deportation case and Civil Case No. 70075 were still pending. At the hearing on the motion, the Solicitor General presented evidence, after which Assad filed a motion to dismiss, which the lower court granted. The Republic appealed.

ISSUE

Whether the lower court erred in granting Assad’s motion to dismiss the petition for cancellation of his certificate of naturalization based on its rulings regarding the admissibility and effect of evidence related to the alleged fraudulent acts.

RULING

The Supreme Court set aside the lower court’s order and remanded the case for further proceedings. The lower court’s conclusions were unsustainable. Regarding charge (a), it improperly excluded the testimony of witnesses (Hilado, Meneses, Lacson) because their testimony had been introduced in other civil cases (Civil Case No. 70075 and Civil Case No. 407), where it was found unworthy of credence. The Supreme Court held this was error because the Republic was not a party to those cases and was not bound by their decisions, which were not yet final; excluding this testimony violated due process. Regarding charge (b), the lower court incorrectly held that Assad’s acquittal in a criminal case for physical injuries (People vs. Jacob Assad, et al.) precluded the government from relitigating the issue. The Supreme Court ruled that an acquittal in a criminal case is not a bar to a subsequent civil action, even one brought by the state, and is not evidence of innocence in such civil action. Regarding charge (f), the lower court held it was not established, interpreting Assad’s testimony that “all the cases were dismissed” as referring only to criminal accusations. The Supreme Court found that Assad’s testimony specifically mentioned a “civil case for annulment” (Civil Case No. 70075) as one of the accusations, and his statement prima facie included such civil and administrative cases unless explained.