Title
IN RE: Yu Nam vs. Republic
Case
G.R. No. L-20016
Decision Date
Apr 29, 1966
The court denied the naturalization application due to the petitioner's omission of his true name and use of aliases, highlighting the necessity of accurate publication to prevent fraud.
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Case Digest (G.R. No. L-20016)

Facts:

  • Emmanuel Yu Nam, the petitioner, applied for Philippine citizenship.
  • His application was initially granted by the Cebu Court of First Instance.
  • The Republic of the Philippines opposed this decision, appealing the court's ruling.
  • The main issue was the use of aliases by the petitioner without judicial approval.
  • Yu Nam's petition stated his name as Emmanuel Yu Nam, which was published.
  • Discrepancies emerged: his birth certificate listed him as Emmanuel Ong, and school records referred to him as Manuel Ong y Lim.
  • These alternative names were not disclosed in the petition, raising jurisdictional concerns.
  • The Republic cited a precedent where similar alias issues led to a naturalization denial due to inadequate public notice.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court of the Philippines ruled in favor of the Republic, reversing the Cebu Court's decision.
  • The petition for citizenship was denied due to improper disclosure of...(Unlock)

Ratio:

  • The Court highlighted that proper publication of a naturalization petition is essential for the process.
  • Publication serves to inform the public about pending applications, allowing for potential objections.
  • The use of aliases without judicial authority misled the public, preventing adequate awareness of the applicant's true ident...continue reading

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