G.R. No. 257697 - San Miguel Corporation vs. Commissioner of Internal Revenue

On February 28, 2002, Edison So filed before the RTC of Manila, Branch 8 (Naturalization Case No. 02-102984) a Petition for Naturalization under Commonwealth Act No. 473, as amended.
He alleged that he was born on February 17, 1982 in Manila; is a Chinese citizen who has lived continuously in Binondo since birth; earns an average annual income of ₱100,000 with board and lodging; is single; speaks English, Chinese, and Tagalog; is exempt from declaration of intention; is of good moral character; believes in constitutional principles; has conducted himself properly; mingles socially with Filipinos; has all qualifications and no disqualifications under Sections 2 and 4 of CA 473; has no criminal convictions or incurable diseases; and intends in good faith to renounce foreign allegiance and reside continuously in the Philippines until admission as a citizen.

The petition was accompanied by the joint affidavit of Atty. Artemio Adasa, Jr. and Mark B. Salcedo, and documents including petitioner’s birth certificate, Alien Certificate of Registration, and Immigrant Certificate of Residence.
On March 22, 2002, the RTC set hearings on December 12 and 17, 2002; ordered publication of the petition and annexes in the Official Gazette and a Manila newspaper for three weeks; and required posting in Manila City Hall.
Petitioner published the order and petition on May 20 & 27, 2002 in the Official Gazette and May 25 & June 1, 2002 in the Today newspaper; no opposition was filed.
At the hearing, witnesses Atty. Adasa and Mark Salcedo testified to petitioner’s good moral character and compliance with statutory requirements. Petitioner testified and offered documents (school records, employment certifications, tax returns, clearances, medical certificates) which were admitted.
On June 4, 2003, the RTC granted the petition, finding petitioner met all qualifications and had no disqualifications; it ordered him admitted as a Filipino citizen upon taking the oath and paying ₱30,000 in costs.

The Republic, through the OSG, appealed to the CA, contending that: (a) the two character witnesses lacked personal knowledge and credibility; and (b) petitioner failed to meet age and other qualifications under CA 473.
On August 4, 2005, the CA reversed and dismissed the petition without prejudice, holding that the witnesses gave only general, statutory recitations and that petitioner was under 21 at the first hearing.
Petitioner’s motion for reconsideration was denied on November 24, 2005.
Edison So then filed a Petition for Review on Certiorari (G.R. No. 170603) before the Supreme Court, raising the sole issue of whether the CA committed reversible error in reversing the RTC decision.

Whether the relaxed qualifications under R.A. No. 9139 for administrative naturalization apply to judicial naturalization proceedings under C.A. No. 473.

Whether the two witnesses presented by petitioner possessed sufficient personal knowledge and credibility to establish his good moral character and compliance with the qualifications and absence of disqualifications under C.A. No. 473.