Case Digest (G.R. No. L-23579)
Facts:
- The case involves the Republic of the Philippines as the petitioner against Hon. Manuel P. Barcelona, Judge of the Court of First Instance of Manila, Branch VIII, and Go Guan as respondents.
- Go Guan filed a petition for naturalization on March 13, 1959, assigned Civil Case No. 39588.
- The court granted Go Guan's petition for citizenship on January 31, 1961.
- On February 20, 1963, Go Guan's counsel requested a hearing after the two-year period required by law.
- Judge Barcelona scheduled the oath-taking hearing for April 6, 1963, but dismissed the case due to the absence of Go Guan and his counsel.
- A motion for reconsideration was filed and granted, resetting the hearing for July 1963.
- On August 1, 1963, the Solicitor General opposed the oath-taking, citing several grounds, including failure to disclose all former residences and lack of evidence of good moral character.
- The court set a hearing for January 18, 1964, but further postponements occurred.
- On April 18, 1964, the court dismissed the petition for oath-taking due to Go Guan's absence, but this dismissal was without prejudice.
- Go Guan filed another motion for a hearing on August 26, 1964, which the State opposed, claiming the previous dismissal rendered the case final.
- On September 26, 1964, Judge Barcelona overruled the State's opposition and set a new hearing for October 3, 1964.
- The Republic of the Philippines then filed a petition for certiorari and prohibition against the judge's order.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the Republic of the Philippines.
- The order of September 26, 1964, was annulled and set aside.
- The decision granting Go Guan's petition for Philippine citizenship was revoked.
- The petition for nat...(Unlock)
Ratio:
- The Supreme Court held that the dismissal of Go Guan's petition to take the oath of allegiance nullified the entire naturalization proceedings.
- The Court emphasized that a judgment in naturalization cases does not become final until the certificate of naturalization is issued and all requirements are fulfilled.
- Previous decisions indicated that denial of the oath-taking equates to nullification of the naturalization process.
- The State raised serio...continue reading
Case Digest (G.R. No. L-23579)
Facts:
The case involves the Republic of the Philippines as the petitioner and Hon. Manuel P. Barcelona, the Judge of the Court of First Instance of Manila, Branch VIII, and Go Guan as the respondents. The events leading to this case began on March 13, 1959, when Go Guan filed a petition for naturalization, which was assigned Civil Case No. 39588. After a hearing, the court, presided over by Judge Juan P. Enriquez, granted Go Guan's petition for citizenship on January 31, 1961. Following this, on February 20, 1963, Go Guan's counsel filed a motion to set the case for hearing after the two-year period required by law. Judge Barcelona scheduled the oath-taking hearing for April 6, 1963, but dismissed the case due to Go Guan's and his counsel's absence. A motion for reconsideration was filed, which was granted, and the hearing was reset for July 1963.
On August 1, 1963, the Solicitor General filed an opposition to the oath-taking, citing several grounds, including the failure to state all former places of residence and the lack of evidence of good moral character. The opposition also claimed that the court lacked jurisdiction due to Go Guan's failure to file a declaration of intention. Despite these objections, the court set a hearing for January 18, 1964. However, further postponements occurred, and on April 18, 1964, the court dismissed the petition for oath-taking due to Go Guan's absence. A motion for reconsideration was subsequently granted, allowing the dismissal to be without prejudice.
On August 26, 1964, Go Guan filed another motion for a hearing prior to oat...