Facts:

The case involves Wayne Chang, also known as Wong Lian, as the petitioner and appellee against the Republic of the Philippines, the oppositor and appellant. The petition for Philippine citizenship was filed in the Court of First Instance of Misamis Occidental. Wayne Chang, originally a native-born Chinese, arrived in Manila on July 8, 1937. He pursued his education in various institutions, finishing high school at Siliman University and completing a Bachelor of Science in Mechanical Engineering at Mapua Institute of Technology in 1956. Following his academic pursuits, he worked at Universal Motors Corporation in Manila from 1958 until the hearing of his petition in April 1962.

On March 21, 1963, Wayne Chang sought to withdraw his application for citizenship, citing the Republic's appeal as the reason. However, the court denied his withdrawal request under the condition that he could refile a new petition in Manila, maintaining the same declaration of intention. The initial p

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Facts:

Petitioner’s Personal Background and Education

• Petitioner, a native-born Chinese, arrived at the port of Manila on July 8, 1937.
• He completed his elementary education in Oroquieta, Misamis Occidental.
• For his secondary education, he attended Misamis Occidental High School, Mindanao Academy, and Siliman University, where he finished high school.
• He pursued higher education in engineering:
• Initially studying engineering for three (3) years at the Gebu Institute of Technology.
• Later completing his B.S. in mechanical engineering at the Mapua Institute of Technology in 1956.
• From 1958 until the hearing of his petition in April 1962, he was employed at the Universal Motors Corporation in Manila.

Petition for Naturalization and Withdrawal Attempt

• The petitioner filed a verified petition for naturalization under the name “Wayne Chang alias Wong Lian” on March 16, 1961.
• On March 21, 1963, he sought permission from the Court to withdraw his petition due to the State’s appeal.
• The Court denied his petition for withdrawal, conditioning any future refile on strict requirements, including the use of the same declaration of intention previously filed.

Jurisdictional and Residency Concerns

• The petition was filed before the Court of First Instance of Misamis Occidental, asserting residency in Oroquieta, Misamis Occidental and at 270 P. Casal, San Miguel, Manila.
• The petitioner’s verified petition failed to mention his other places of residence, which included:
• Cebu City
• Dumaguete City
• Additional addresses in Manila (1242-A Abreu Street, 1950 Arellano Street, 747 Padilla Street, and 242 P. Casal Street)
• The facts indicated that petitioner had not resided in Misamis Occidental for at least one year immediately preceding the filing of his petition, a requirement under the Naturalization Law.

Use of Aliases and Identity Issues

• The petition was filed in the name “Wayne Chang alias Wong Lian” though previous judicial proceedings had altered his name.
• On February 25, 1956, the Court of First Instance of Misamis Occidental approved his application to change his name from “Wong Lian alias Chang Wingkoy, alias Chang Wing” to “Wayne Chang.”
• Petitioner used various names in different contexts:
• “Wong Lian” in his Landing Certificate of Residence and Alien Certificate of Registration.
• “Chang Wingkoy” in school records at Holy Rosary School in Oroquieta and at Siliman University in Dumaguete.
• The unauthorized use of several aliases without proper judicial authorization was deemed to render him unworthy of Philippine citizenship.

Issue:

• Whether the petition was filed before a court holding exclusive original jurisdiction given petitioner’s residency claims, particularly his failure to establish at least one year’s residence in Misamis Occidental immediately prior to filing.
• Whether the omission of several places of residence in the verified petition constitutes a fatal defect in establishing eligibility for naturalization under the Naturalization Law.
• Whether the petitioner’s use of multiple names or aliases in his dealings with the public, without judicial authorization for such changes, disqualifies him from acquiring Philippine citizenship.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)