Facts:

The case involves Miguel Chun Eng Go, the petitioner-appellant, who sought to be admitted as a citizen of the Philippines. The petition was filed in the Court of First Instance of Cebu, where it was dismissed on July 18, 1967. Miguel Chun Eng Go, born on October 26, 1935, in Manila, is a subject of Nationalist China and claimed to have continuously resided in the Philippines for 24 years. At the time of filing, he resided at No. 71 R.R. Landon St., Cebu City, having previously lived at Sikatuna St. in the same city. He worked as a purchasing agent earning an annual income of P2,400.00, was single, and could communicate in English and the Cebu-Visayan dialect. The petition cited Section 3 of Commonwealth Act 473, which allows for a reduced residency requirement for naturalization from ten years to five years for those born in the Philippines.

However, the evidence revealed that during World War II, when he was about six or seven years old, he and his family evacuated to var...

Facts:

1. Petitioner's Background:

   • Miguel Chun Eng Go, a subject of Nationalist China, was born in Manila on October 26, 1935.
   • He has continuously resided in the Philippines for 24 years since birth.
   • At the time of filing the petition, his residence was at No. 71 R.R. Landon St., Cebu City, and his former residence was at Sikatuna St., Cebu City.
   • He is a purchasing agent earning P2,400.00 annually, single, and fluent in English and the Cebu-Visayan dialect.

2. Legal Basis for Petition:

   • Petitioner claims entitlement to the benefit under Section 3 of Commonwealth Act 473, which reduces the 10-year continuous residence requirement to 5 years for those born in the Philippines.
   • He asserts that he possesses all qualifications for naturalization and none of the disqualifications.

3. Residence Details:

   • During World War II, petitioner and his family evacuated to D. Jakosalem, Catmon, and Paknaa-an, Mandawe, Cebu.
   • After liberation, he resided at Sikatuna Street, Cebu City.
   • In 1957, he moved to Manila as a student and stayed with his grandparents at Antonio Rivera Street for four years.
   • Petitioner failed to disclose all these former residences in his petition, mentioning only his present residence (No. 71 R.R. Landon St.) and former residence (Sikatuna Street).

4. Trial Court Decision:

   • The Court of First Instance of Cebu dismissed the petition due to petitioner's failure to allege all former places of residence.

Issue:

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Ruling:

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Ratio:

1. Purpose of the Law:

   • Section 7 of the Revised Naturalization Law requires the petitioner to state all present and former places of residence. This requirement is intended to inform the public and enable them to register objections through government agencies.
   • Omitting some residences deprives the public of the opportunity to object intelligently, defeating the purpose of the law.

2. Actual vs. Legal Residence:

   • The Court emphasized that the requirement includes both legal and actual/physical residence.
   • Actual residence is crucial because it is where the petitioner's conduct and character are most evident. People in his actual surroundings are better positioned to judge his fitness for citizenship.
   • Legal residence, on the other hand, may not provide a complete picture of the petitioner's character, as it could be a place where he seldom stays.

3. Jurisdictional Requirement:

   • The inclusion of all former residences is a jurisdictional requirement. Failure to comply renders the petition fatally defective, and this defect cannot be cured by presenting evidence of the omitted residences during the trial.

4. Solicitor General's Argument:

   • While the Solicitor General argued that the petitioner did not falsify or conceal information intentionally, the Court ruled that the omission itself is sufficient to dismiss the petition, regardless of intent.

Conclusion:

The Supreme Court upheld the trial court's dismissal of the petition, ruling that the failure to state all former residences is a fatal defect that deprives the court of jurisdiction. The requirement to disclose all residences, both legal and actual, is essential to ensure transparency and public participation in the naturalization process.