Case Digest (G.R. No. 200983)
Facts:
Republic of the Philippines v. Huang Te Fu, G.R. No. 200983, December 7, 2015, Supreme Court Second Division, Del Castillo, J., writing for the Court.
On March 19, 2004, Huang Te Fu a.k.a. Robert Uy (herein respondent), a national of the Republic of China (Taiwan), filed a sworn Declaration of Intent to Become a Citizen of the Philippines with the Office of the Solicitor General. On April 27, 2005 respondent filed a formal Petition for Naturalization in the Regional Trial Court (RTC) of Quezon City, docketed as Special Procedure No. Q-05-55251 and assigned to Branch 96. The petition recited respondent's birth in Taiwan (August 15, 1976), continuous residence in the Philippines since August 13, 1982, marriage to a Filipino citizen, two Philippine-born children, claimed occupation as businessman/general manager in the family zipper-manufacturing enterprise, and an average monthly income of P15,000. Respondent attached an original certification of arrival, his declaration of intent, affidavits of two Filipino witnesses, and photographs.
After trial the RTC (Judge Afable E. Cajigal) issued an Order dated September 24, 2007 granting the petition and declaring respondent admitted to Philippine citizenship, subject to a two-year period during which the court would determine continued compliance with specified conditions. The Solicitor General appealed to the Court of Appeals (CA), which docketed the case as CA-G.R. CV No. 91213.
In the CA appeal, the Solicitor General challenged respondent's compliance with Commonwealth Act No. 473 (CA 473)—arguing that respondent (1) did not own real estate, (2) lacked a known lucrative trade or lawful occupation, (3) was not gainfully employed but merely received allowances from his parents, (4) had falsely represented himself as a Filipino in an August 2001 Deed of Sale involving property in Antipolo, (5) had discrepancies between his petition-stated income and income tax returns suggesting tax evasion or concealment, and (6) could not cite principles underlying the Constitution on cross-examination. Respondent replied that he had limited involvement in preparing certain documents, did not personally file tax returns, received variable salary and parental support, and had sworn belief in constitutional principles.
On November 29, 2011 the CA (penalty authored by Associate Justice Franchito N. Diamante, with Presiding Justice Andres B. Reyes, Jr. and Associate Justice Mariflor P. Punzalan Castillo concurring) affirmed the RTC, finding respondent engaged in a lucrative occupation as general manager of the family business, explaining income discrepancies, and rejecting the weight given to the deed-of-sale representation and the cross-examination on constitutional principles. The CA denied reconsideration in a Ma...(Pro-only)
Issues:
- Whether respondent has shown full and complete compliance with the requirements of Commonwealth Act No. 473 (the Revised Naturalization Law)—in particular the requisites of having a known lucrative trade or lawful occupation and of good moral character—so as to entitle h...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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