G.R. No. 210412 - Republic vs. Karbasi

On June 25, 2002, Kamran F. Karbasi, an Iranian national recognized as a Person of Concern by the UNHCR, filed a judicial petition for naturalization with the RTC of Dipolog City under Commonwealth Act No. 473. He alleged continuous residence in the Philippines since July 11, 1990, marriage to a Filipino citizen, one child, ownership of a repair business, proficiency in English and Visayan, and good moral character.
He claimed compliance with procedural requirements (Declaration of Intention filed May 25, 2001), qualifications under Section 2, and absence of disqualifications under Section 4 of Commonwealth Act No. 473.

The RTC found the petition sufficient, issued publication orders (Official Gazette, local paper), and set hearings. No objections were filed.
During hearings (2003–2006), two Filipino character witnesses and his wife testified to Karbasi’s good reputation, community integration, and capacity as a provider. Karbasi testified on his flight from Iran (using an assumed name), refugee status, education (vocational and college diplomas), business operations, and family life. He offered exhibits including identity documents, UNHCR certifications, tax clearances, business permits, and service contracts.
On January 17, 2007, the RTC granted the petition, finding Karbasi met all qualifications. The Republic, via the OSG, appealed to the Court of Appeals (CA).

On January 29, 2013, the CA affirmed the RTC, rejecting OSG arguments on inadequate income, reciprocity, and underdeclaration of income.
The OSG filed a petition for certiorari under Rule 45, raising legal issues on income sufficiency, moral character, and reciprocity. Karbasi opposed, citing international refugee‐law obligations and DOJ Circular No. 58 (Series 2012).

Whether Karbasi’s trade or occupation yields a “lucrative income” as required by Section 2(4) of Commonwealth Act No. 473.
Whether the alleged underdeclaration of income in Karbasi’s ITRs reflects a lack of the “proper and irreproachable” moral character mandated by Section 2(3).
Whether, as a recognized refugee, Karbasi must prove reciprocity between Iranian and Philippine naturalization laws under Section 4(1).