G.R. No. 220674 - Mohamed vs. Republic

Sefyan Abdelhakim Mohamed (Mohamed), a Sudanese national, married to a Filipino citizen, Lailanie N. Piano, with whom he has a child.
He arrived in Manila in 1991 and was recognized as a convention refugee in 2005.
He works as a Public Relations Officer at the Qatar Embassy earning $800 monthly.

On June 2, 2006, Mohamed filed a Declaration of Intention with the Office of the Solicitor General (OSG).
On July 20, 2007, he submitted a Supplemental Declaration of Intention including an additional alias.
On August 21, 2007, he filed a Petition for Naturalization before the Regional Trial Court (RTC) of Pasay City.
He presented two witnesses, Edna A. Hussein and Mary Joy S. Amigable, during the trial.

The RTC granted Mohamed’s naturalization petition on October 7, 2009, finding he met the qualifications required under law.
Mohamed moved to take his oath of allegiance on September 20, 2011, asserting compliance with all legal requisites during the required two-year period.
After some disputes regarding his travel abroad for work during the two-year period, the RTC allowed him to take his oath on September 24, 2012.
Mohamed took his oath of allegiance on October 24, 2012.

The OSG contested the petition on grounds that the Declaration of Intention was filed less than one year before the petition for naturalization, violating statutory requirements.
The OSG also challenged the sufficiency and credibility of evidence regarding Mohamed’s qualifications and the validity of the oath of allegiance taken before the expiration of the government’s appeal period.
The Court of Appeals (CA) reversed the RTC ruling on February 25, 2015, dismissing the petition for naturalization without prejudice and declaring the oath of allegiance void.
Mohamed’s motion for reconsideration was denied, prompting the filing of the current petition.

Mohamed insists the one-year period should be reckoned from the original Declaration on June 2, 2006, not the supplemental one; he claims compliance with all requirements, good faith in taking his oath, and invokes the 1951 Refugee Convention and precedents favoring refugee naturalization.
The OSG maintains that Mohamed’s failure to comply with the one-year period is a fatal jurisdictional defect, witnesses' testimonies are inadequate, and the premature oath invalidates the naturalization.

Whether or not the supplemental Declaration of Intention filed by Mohamed reset the one-year statutory waiting period prior to filing the petition for naturalization.
Whether or not the evidence presented by Mohamed sufficiently established his qualifications, including mental and physical fitness, and credibility of witnesses required by law.
Whether or not the oath of allegiance taken by Mohamed before the expiration of the government’s appeal period is valid and effective.
The effect of the Philippines’ obligations under the 1951 Convention relating to the Status of Refugees on the naturalization requirements.