Facts:

• Petitioner-appellee Tiu To Kiat sought Philippine citizenship.
• The lower court initially approved his application and granted him a certificate of naturalization.
• The Republic of the Philippines, represented by Solicitor General Antonio P. Barredo and Solicitor P. Pardo, opposed the application.
• The Republic cited grave jurisdictional defects: failure to state former places of residence and non-compliance with educational requirements for minor children.
• The lower court denied the Republic's petition for cancellation, attributing the omission to an oversight by Tiu To Kiat's former counsel.
• The Republic appealed, leading to the present case before the Supreme Court.
• The case was decided on March 25, 1974, by the Second Division of the Supreme Court, with Justice Fernando penning the decision.

Issue:

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Ruling:

1. Yes, the Supreme Court ruled that the failure to state former places of residence in the petition for naturalization is a fatal flaw that warrants the cancellation of Tiu To Kiat's certificate of naturalization.
2. The Supreme Court did not need to pass j...(Unlock)

Ratio:

• The Supreme Court's decision was based on the strict requirements of Section 7 of the Revised Naturalization Law.
• This law mandates that a petitioner must state both their present and former places of residence in their petition.
• The requirement ensures that the public and investigating agencies are fully informed and can voice any objections.
• The Court cited precedents such as Lo v. Republic, Koa Gui v. Republic, De Lara v. Republic, and Gaw Ching v. Republic.
• These precedents consistently held that the omission of former places of residence is a g...continue reading