G.R. No. 19829 - IN RE: Republic vs. Co Keng

Francisco Co Keng filed a petition for naturalization in the Court of First Instance of Manila, claiming to possess all qualifications and none of the disqualifications for Philippine citizenship.
He alleged he was a merchant with an annual income of P18,000.00, residing at No. 428 Sto. Cristo, Manila.
He was born in Amoy, China, on August 26, 1920, married to Yao Sok Ti (Dolores Yao), and had two children, Roberto and Francisco Jr., born in 1951 and 1954, respectively.
He claimed to speak and write English and Tagalog.

On October 31, 1956, the court granted his petition for naturalization.
On December 29, 1958, after two years and with no objection from the Solicitor General, Co Keng took the oath of allegiance as a Filipino citizen.

On March 7, 1961, the Solicitor General filed a motion to cancel Co Keng’s certificate of naturalization, alleging fraud.
The motion claimed Co Keng falsely represented his residence as No. 428 Sto. Cristo, Manila, when he actually resided at No. 28, 12th Street, Broadway, Quezon City.
It also alleged that Co Keng engaged in tax evasion and questionable activities detrimental to the country’s economic interests.

The Solicitor General submitted public documents showing Co Keng’s residence as Quezon City, including:

A verified petition for special administration of his father’s estate (Exhibit A).
Birth certificates of his children (Exhibits B and C).
Tax declarations for real property in Quezon City (Exhibit AA).
Corporate documents listing his residence as Quezon City (Exhibits Y-5, Y-6, Y-1).
Income tax returns (Exhibit SSS).

Co Keng argued that the Quezon City address was a “second address” and not a residence.
He claimed the information in his children’s birth certificates was provided by others and was a “mistake.”
He admitted using the Quezon City address for convenience but maintained his primary residence was in Manila.

Whether Francisco Co Keng obtained his certificate of naturalization through fraud by misrepresenting his residence.
Whether Co Keng’s habitual tax evasion and underdeclaration of income disqualified him from possessing the good moral character required for naturalization.
Whether the trial court erred in granting Co Keng’s petition for naturalization despite non-compliance with legal requirements.