G.R. No. 175251 - Luna vs. Allado Construction Co., Inc.

Jimmy Lee, a Chinese national, sought to be admitted as a citizen of the Philippines.
He filed his petition for naturalization on November 17, 1956, before the Court of First Instance of Iloilo in Special Proceedings No. 54.
The petition was accompanied by several documents:

A declaration of intention to become a Filipino citizen, originally sent to the Office of the Solicitor General by registered mail on October 23, 1953.
A copy of an order from the Court of First Instance of Iloilo (Special Proceedings No. 1219) authorizing him to change his name from Yip Hap to Jimmy Lee.
The affidavit of his character witnesses.

Although Jimmy Lee’s declaration of intention was allegedly sworn to and dispatched in 1953, the required filing fee of P10.00 was not paid at that time.
The filing fee was eventually remitted on May 23, 1956, upon demand, which was significantly delayed compared to the original submission date.
The law required that the declaration of intention, along with the fee, be filed at least one year prior to the petition for naturalization.

The Solicitor General, acting through the City Fiscal of Iloilo, filed an opposition on the general ground that Jimmy Lee did not fulfill all the requisites for naturalization—particularly, the timely payment of the filing fee.
After a trial, on August 15, 1958, the lower court rendered judgment admitting Jimmy Lee to Philippine citizenship.
This judgment became final and executory because the Office of the Solicitor General filed the record on appeal beyond the reglementary period.

Upon a re-examination of the case documents, the Solicitor General discovered that the declaration of intention’s effective filing was delayed due to the late payment of the filing fee.
Concerns were raised regarding non-compliance with the one-year jurisdictional requirement embodied in Section 5 of the Naturalization Law (as amended).
Consequently, on October 29, 1958, the Solicitor General filed a motion to annul the proceedings on the ground that the necessary fee payment was made only on May 23, 1956—barely 5 1/2 months before the petition for naturalization was filed.

The lower court denied the Solicitor General’s motion to annul the proceedings in its order dated December 6, 1958.
Dissatisfied with this outcome, the Solicitor General elevated the matter to appeal, prompting the current judicial review of the case.

Did Jimmy Lee’s filing of his declaration of intention comply with the statutory requirement of being filed at least one year before the filing of the petition for naturalization?
Was the delayed payment of the filing fee legally acceptable, or did it vitiate the effectiveness of the declaration of intention?

Does the failure to pay the requisite filing fee at the time of submitting the declaration of intention render the naturalization proceedings null and void?
Should the subsequent naturalization petition be annulled on the basis that the effective filing date of the declaration of intention is considered May 23, 1956, thereby disqualifying the petitioner due to non-compliance with the one-year requirement?

How should the court apply the principle, as seen in Lazaro vs. Endencia, regarding incomplete payment or improper submission of necessary fees in legal proceedings to this naturalization case?