G.R. No. L-15955 - IN RE: Ching vs. Republic

Narciso Ching, the petitioner and appellee, filed a petition for naturalization under the Revised Naturalization Law (Commonwealth Act No. 473).
The petition was reviewed by the Rizal court of first instance, which originally granted his naturalization.

Commonwealth Act No. 473 requires that an applicant for naturalization must be of good moral character and must explicitly state his belief in the principles underlying the Philippine Constitution.
The petition must contain a declaration by the applicant that he meets the qualifications prescribed by the Act, including an explicit assertion of his allegiance to the Constitution.

The official petition form, as prescribed under Section 21 of the Naturalization Act, includes a clause wherein the applicant must state, “I believe in the principles underlying the Philippine Constitution.”
The petition filed by Narciso Ching did not contain any assertion or declaration regarding his belief in the principles of the Philippine Constitution.
At the hearing, when questioned regarding this requirement, Ching did not make any declaration to cure this omission.

The Solicitor-General, representing the Republic of the Philippines, objected to the petition on the grounds that:

There was a failure by the petitioner to allege and prove his belief in the principles underlying the Philippine Constitution.
The petitioner did not show continuous residence in the Philippines from the filing of his petition until his presumed admission to citizenship.

The government emphasized that the explicit declaration is an essential element in the petition for naturalization.

Whether Narciso Ching’s petition for naturalization is valid despite the omission of an explicit declaration of his belief in the principles underlying the Philippine Constitution.
Whether an oral statement made at the hearing, wherein the petitioner stated his belief in the ideals of the Filipino people, can cure the absence of a written declaration in the petition.