G.R. No. 173988 - Rosaldes vs. People

Petitioner Ong Chia was born on January 1, 1923 in Amoy, China, and arrived in Manila in 1932 at age nine.
He established residency in the Philippines, found employment, started a business, married Ramona Villaruel, and sired four children.

On July 4, 1989, at age 66, Ong Chia filed a verified petition for naturalization under Commonwealth Act No. 473 (Revised Naturalization Law), alleging compliance with eligibility requirements (A2) and absence of disqualifications (A3).
During trial, the State presented no opposing evidence; the public prosecutor expressed support for the petition.
On August 25, 1999, the Regional Trial Court (Koronadal, Branch 24) granted the petition.
The Office of the Solicitor General appealed, arguing that Ong Chia:

Failed to state all names used (omitted “Loreto Chia Ong”).
Omitted former places of residence (e.g., J.M. Basa St., Alimodian, Iloilo).
Did not conduct himself with proper and irreproachable behavior (cohabited without valid marriage from 1953 to 1977).
Lacked a known lucrative trade or occupation; income tax returns (1973–1977) showed insufficient earnings.
Did not formally offer documentary evidence at trial.

The Court of Appeals, in a November 15, 1996 decision, reversed the trial court, holding that in naturalization cases the State may advance new grounds on appeal and that petitioner’s omissions and conduct disqualified him.

Can the appellate court consider documents annexed for the first time on appeal in naturalization proceedings, despite the absence of formal offer under the Rules on Evidence?

Does failure to state all names ever used (e.g., “Loreto Chia Ong”) in the petition render it fatally defective?
Does omission of former places of residence violate Section 7 (A7) and warrant denial?
Does prolonged cohabitation without valid marriage constitute lack of “proper and irreproachable conduct” under A2?
Does insufficient or unverified income disqualify an applicant for lacking a “known lucrative trade or occupation”?