G.R. No. L-77278 October 18, 1988
In the Matter of the Petition of Felly Lee Fong Sheng to be admitted a citizen of the Philippines. FELLY LEE FONG SHENG, petitioner-appellee, vs. REPUBLIC OF THE PHILIPPINES, oppositor-appellant.

FACTS

Felly Lee Fong Sheng filed a petition for naturalization before the Regional Trial Court of Quezon City. The trial court granted her application, finding she possessed all qualifications and none of the disqualifications for Philippine citizenship. The Republic of the Philippines appealed the decision, raising several grounds for reversal.
The government’s opposition highlighted specific deficiencies: the petitioner failed to state her present and former places of residence accurately in her petition; her annual income of P24,000 was argued to be insufficient for her and her three dependent school-age children; she demonstrated ignorance of constitutional principles and citizenship duties; and her character witnesses were allegedly not competent.

ISSUE

Whether the Regional Trial Court erred in granting Felly Lee Fong Sheng’s petition for naturalization.

RULING

The Supreme Court reversed the trial court’s decision and dismissed the petition. The ruling centered on the petitioner’s fatal non-compliance with statutory requirements and the resulting implications for her moral character. The Court found that the petitioner violated Section 7 of Commonwealth Act No. 473 , which mandates that a naturalization petition must set forth the applicant’s present and former places of residence. In her petition, she listed No. 1595 Quezon Avenue, which was determined to be a furniture store. She later admitted under oath that she used this address only for convenience in receiving mail, while actually residing in Barangay Kaybiga, Novaliches, Quezon City—an address she omitted from her petition.
This omission was deemed a fatal defect. The Court, citing precedent, explained that the residency disclosure requirement is crucial to facilitate background checks on the applicant’s qualifications and moral character by both private individuals and government agencies. By falsifying her true residence, the petitioner demonstrated a lack of the good moral character required for naturalization. Furthermore, the Court noted an additional legal impediment: the petitioner, a Chinese citizen, was legally married to a Chinese national. Granting her Philippine citizenship while her husband remained a foreign national would create an anomalous situation of potential double allegiance, as she might also be considered a national of her husband’s country under its laws. This compounded the disqualification. The petition was therefore dismissed.