G.R. No. 200983 - Republic vs. Huang Te Fu

Respondent Huang Te Fu, also known as Robert Uy, a citizen of the Republic of China (Taiwan), filed a Declaration of Intent to Become a Citizen of the Philippines on March 19, 2004 with the Office of the Solicitor General.
On April 27, 2005, he filed his Petition for Naturalization with the Regional Trial Court (RTC) of Quezon City, Branch 96, under Nat. Case/Spec. Proc. No. Q-05-55251.
The petition included detailed personal information such as his full name, past and present residential addresses, trade or profession (businessman engaged in zipper manufacturing), educational background (primary, secondary, and college education in the Philippines), language proficiency, and family details including his marriage to a Filipino citizen and their two children.
He affirmed that he had continuously resided in the Philippines for over 23 years, attended Philippine Cultural High School and Ateneo de Manila University, and that he had no criminal or disqualifying record under Commonwealth Act No. 473.

The petition was supported by documentary evidence, which included the Original Certification of Arrival issued by the Bureau of Immigration, a sworn Declaration of Intent, affidavits from two Filipinos (Atty. Benjamin Moraleda, Jr. and Atty. Bella Ramona Antonano), as well as recent photographs of the applicant.
At trial, respondent testified regarding the details of his birth, educational attainment, work history—including his appointment as general manager of his family’s zipper manufacturing business—and his consistent adherence to the principles underlying the Philippine Constitution.
Multiple witnesses verified his qualifications, emphasizing that he possessed all the necessary qualifications and did not fit any disqualifications under the Revised Naturalization Law.

The trial court issued an Order on September 24, 2007 granting the naturalization petition on the basis that respondent satisfied the requirements concerning good moral character and qualifying employment.
The Court of Appeals (CA) later affirmed the trial court’s ruling (Decision dated November 29, 2011) based on evidence of his engagement in a lucrative trade, his alleged earnings in support of his family, and other testimonial evidence.
However, questions arose regarding the consistency of his income declarations, his actual employment status (highlighted by his non-inclusion in the payroll of his family business), and an incident involving his signature on a deed of sale that falsely represented him as a Filipino citizen.

Asserted that respondent did not truly engage in a lucrative trade or lawful occupation because his declared monthly earnings (P15,000.00 to P18,000.00) were insufficient to support his family.
Pointed to inconsistencies between the income declared in the petition and those shown in his income tax returns, suggesting tax evasion or concealment of his true income.
Highlighted that respondent’s act of signing the deed of sale—which falsely indicated his status as a Filipino citizen—infringes upon his good moral character and violates constitutional restrictions on foreign land ownership.
Noted that during cross-examination, respondent was unable to recite or clearly articulate the principles underlying the Philippine Constitution, which was used to question his allegiance and belief in Filipino values.

Claimed that the discrepancies in his tax returns and personal testimony were due to the fact that he did not personally file his returns and that his salary varied from month to month as it was disbursed directly by his parents.
Asserted that his signature on the deed of sale was made without full awareness of the implications and that it was executed at the request of a broker for property registration purposes in his wife’s name.
Maintained that his failure to recite the constitutional principles verbatim did not equate to disbelief in them, as his affirmative declaration under oath proved his allegiance to the Constitution.

Whether respondent has fully complied with the rigid and stringent requisites imposed by Commonwealth Act No. 473 (the Revised Naturalization Law) necessary to be admitted as a citizen of the Philippines.

Is the evidence presented sufficient to demonstrate that respondent has a known lucrative trade, profession, or lawful occupation capable of supporting his family independently?
Do the inconsistencies in his income declarations and his non-inclusion on the payroll of his family business evidence an intention to evade taxes or conceal material facts?
How should the false declaration contained in the deed of sale, which misrepresented his citizenship status, be viewed in assessing his good moral character?
Is the respondent’s inability to explicitly recite the underlying principles of the Philippine Constitution during cross-examination a valid ground for questioning his allegiance and moral integrity?