Case Digest (G.R. No. L-11152)
Facts:
Benito Co v. Republic of the Philippines, G.R. No. L-11152. May 23, 1958, the Supreme Court En Banc, Felix, J., writing for the Court. Petitioner Benito Co filed an application for naturalization on August 23, 1955, accompanied by a joint affidavit of sponsors/character witnesses (Messrs. Augusto N. Aguilar, Dominador Cruz and Dionisio F. Coronel—Exh. A). Notice of hearing was published in the Voz de Manila and the Official Gazette. At the hearing petitioner and two sponsoring witnesses (Aguilar and Coronel) testified and numerous exhibits (A through CC) were offered; the transcript explains the exhibits (pp. 69–75).The petition alleged (and the trial court found) petitioner was born in Amoy, China (Dec. 1915), arrived in the Philippines in 1926, and had continuously resided in the Philippines and in Manila for the year immediately preceding filing; he was married to Rosario Tan and had four children; he worked as a building contractor (≈P3,000 annual income), paid taxes, could read, speak and write English and Tagalog, and had registered as an alien under Republic Act No. 562. The petition also averred petitioner believed in the principles of the Philippine Constitution, intended in good faith to renounce foreign allegiance (to China), was not a polygamist, had no conviction involving moral turpitude, and was not affiliated with anti-government organizations.
Two witnesses (Aguilar and Coronel) testified they personally knew petitioner, vouched for his good repute, and declared he met the qualifications and none of the disqualifications under the Revised Naturalization Law (Commonwealth Act No. 473). The Solicitor General’s Office represented the Government but presented no evidence and did not oppose the petition in writing or orally.
The trial court denied the petition. The judge characterized the witnesses’ testimony as “vacillating, incomplete and unsatisfactory,” labeled much of their testimony as hearsay and their knowledge as casual, and, separately, delivered an extended statement warning against granting citizenship to foreigners allegedly motivated by economic self-interest—stating the court must interpret the law strictly to protect national patrimony and infant industries. Petitioner appealed, arguing the denial was contrary to law and unsupported by the evidence.
The Supreme Court reviewed the transcript and exhibits. It found the affidavit and testimony showed personal, long-standing acquaintance (dating to 1941) and specific knowledge of petitioner’s family, residence and associations, satisfying the proof required by Section 7, Commonwealth Act No. 473. The Court also observed petitioner successfully answered language and civics examinations. Conc...(Subscriber-Only)
Issues:
- Did the trial court err in finding the sponsoring witnesses’ testimony vacillating, incomplete and insufficient to support the naturalization petition?
- Did the trial court lawfully apply an extra-statutory policy (nationalistic/economic concerns) in denying naturalization, or did it exceed the statutory scheme of Commonwealth Act No. 473?
- Was the evidence sufficient to establish that petitioner met the qualifications of Section 2 and none of the disqualifications of Section 4...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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