Facts:

• Go Pei Hung, a British subject and resident of Hong Kong, filed a petition for naturalization in the Philippines on December 3, 2007.
• The petition was filed before the Regional Trial Court (RTC) of Manila, Branch 16, under Naturalization Case No. 07-118391.
• On July 21, 2010, the RTC granted Go Pei Hung's petition for naturalization, determining that he met all qualifications under Section 2 of Commonwealth Act No. 473 (CA 473), the Revised Naturalization Law.
• The Court of Appeals (CA) upheld the RTC’s decision on February 28, 2014, in CA-G.R. CV No. 97542 and denied the Republic's motion for reconsideration on June 5, 2014.
• The Republic of the Philippines, through the Office of the Solicitor General (OSG), appealed the CA’s decision, arguing that Go Pei Hung did not meet several statutory requirements, including:
  • Filing a Declaration of Intention,
  • Attaching a Certificate of Arrival,
  • Demonstrating a lucrative trade, profession, or occupation,
  • Presenting credible character witnesses.

Issue:

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Ruling:

• The Supreme Court granted the petition filed by the Republic of the Philippines.
• The Court reversed and set aside the February 28, 2014 Decision and June 5, 2014 Resolution of the Court of Appeals.
• Consequently, the respondent's Petition fo...(Unlock)

Ratio:

• The Supreme Court emphasized the need for strict compliance with the statutory requirements of the naturalization law.
• The Court found that Go Pei Hung failed to attach a Certificate of Arrival to his Petition for Naturalization, a mandatory requirement under Section 7 of CA 473.
• The Certificate of Arrival is crucial as it proves the applicant entered the country legally; its absence renders the petition incomplete and must be denied outright.
• The Court clarified that the Declaration of Intention and the Certificate of Arrival are separate requirements,...continue reading