Case Digest (G.R. No. 227600)
Facts:
Ho Ching Yi v. Republic of the Philippines, G.R. No. 227600, June 13, 2022, Supreme Court Second Division, Leonen, SAJ, writing for the Court.Petitioner Ho Ching Yi filed a petition for naturalization on September 17, 2010, alleging she is a Taiwanese national who arrived in the Philippines in 1994 and had continuously resided in the country for more than ten years. The petition averred that since 2009 she had worked as treasurer of Tungtay Trading and Manufacturing Corporation with an average annual income of ₱240,000, and it was supported by affidavits and the testimony of two former tutors, Mary Ann R. Tamondong and Maritess S. Adaon.
The Regional Trial Court (RTC), Malolos City, Branch 9, conducted hearings and, by Decision dated July 31, 2014, denied the petition. The RTC found the two witnesses insufficient to establish petitioner’s qualifications and doubted their credentials and the basis for testifying on her moral character; it observed inconsistencies in petitioner’s income statements and found those inconsistencies undermined the claim of good moral character. The RTC concluded there was insufficient evidence that petitioner met all qualifications and no disqualifications under the Naturalization Law.
Petitioner appealed to the Court of Appeals (CA). In a June 7, 2016 Decision (with an October 10, 2016 Resolution denying reconsideration), the CA affirmed the RTC, agreeing that the witnesses were inadequate and that unexplained inconsistencies regarding petitioner’s stated average annual income remained. Petitioner then brought a Petition for Review on Certiorari to the Supreme Court under Rule 45, challenging only the CA’s finding that her witnesses were not credible and also reiterating explanations for the decline in her...(Subscriber-Only)
Issues:
- Did petitioner establish that her attesting witnesses were “credible persons” as required by Commonwealth Act No. 473, section 7?
- Even assuming the witnesses were credible persons, did their testimony sufficiently and competently prove petitioner’s moral character and other qualificati...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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