G.R. No. L-10912 - Lim Hok Albano vs. Republic

The appellant, Anselmo Lim Hok Albano (also known by the aliases Lim Hok and Lim Hok Anselmo Albano), filed a petition for naturalization.
His petition was duly tried and granted by the Court of First Instance of Ilocos Norte.
Following the required two-year probational period under Section 1, Republic Act No. 530, a petition was filed for his oath-taking and issuance of a naturalization certificate.

After the probationary period, the lower court, upon hearing the petition for oath-taking, denied the same.
The denial was based on allegations that the appellant had been using multiple aliases in violation of Commonwealth Act No. 142 (the Anti-Alias Law).
It was contended that his full name, as submitted, was “Anselmo Lim Hok Albano, alias Lim Hok, alias Lim Hok Anselmo Albano,” a practice claimed to be illegal.

The appellant argued that since the same court that granted his naturalization petition had jurisdiction to hold a subsequent hearing regarding his qualifications, the issue of alias usage should have been raised during the initial proceedings.
He maintained that any objection based on his use of aliases must be interposed at the earlier stage, asserting that the subsequent raising of the issue was procedurally improper.
Precedents were cited (Lim Lian vs. Republic of the Philippines and Yap Chin, alias Jose Go Tanse vs. Republic of the Philippines), emphasizing that questions affecting an applicant’s qualifications may be raised at any stage of the proceedings.

The decisive question was whether the appellant’s use of aliases fell within the ambit of Commonwealth Act No. 142.
It was noted that the law does not penalize the use of a name by which a person has been known from childhood.
The appellant had been known as “Lim Hok” since his early years, and although he was baptized as Anselmo Lim Hok, he regularly added “Albano” (the surname of his godfather, Dionisio Albano) in business and social dealings to emphasize his identity.
There was no evidence that this practice caused any confusion or prejudice, which is the primary concern of Commonwealth Act No. 142.

Whether the appellant’s continued use of aliases, including variations of his name, constitutes a violation of Commonwealth Act No. 142 (the Anti-Alias Law).

Does the use of a childhood name in conjunction with an additional surname amount to fraud or misrepresentation under the law?

Whether the lower court erred in denying the appellant’s petition for oath-taking and issuing the naturalization certificate on the ground of alleged illegal alias usage.

Was it proper to base the denial on the argument that the petitioner employed aliases, even though he had been known by one of these names since childhood?

Whether procedural rules allow issues regarding an applicant’s qualifications—such as the use of aliases—to be raised at later stages of the naturalization proceedings, even after the petition has been initially granted.

Can opposition based on allegations concerning alias usage be effectively interposed after the naturalization petition has been granted?