Case Summary (G.R. No. 224097)
Background of the Case
The petitioner sought Philippine citizenship through a petition filed before the Court of First Instance of Cebu. Previously, on August 15, 1951, the Solicitor General initiated a petition to cancel the certificate of naturalization previously granted to Go Bon Lee, primarily because he failed to enroll his minor children in a public or private school in the Philippines, as stipulated by the Naturalization Law. Following a subsequent appeal, the higher court revoked his certificate of naturalization, signifying the impact of his failure to meet the schooling requirements.
Previous Attempts and Legal Proceedings
After the revocation of his naturalization certificate, the petitioner filed a new petition on June 23, 1961, in an attempt to remedy the deficiencies identified in the prior case. However, the City Fiscal of Cebu reiterated the same grounds for opposition, emphasizing the petitioner’s failure to send his children to recognized educational institutions. After considering the evidence presented by both parties, the Court denied the petition and the petitioner subsequently appealed the decision.
Petitioner’s Arguments
The petitioner argued that he should be exempt from the schooling requirement due to significant challenges he faced in bringing his children to the Philippines. He contended that despite his efforts, circumstances beyond his control—including a lack of consent from his mother-in-law and travel-related health concerns—prevented him from fulfilling the requirements of the Naturalization Law.
Court’s Analysis and Findings
The Court found no merit in the petitioner’s claims. It highlighted that objections from the mother-in-law about the children’s health did not serve as a valid insurmountable obstacle to their migration. Additionally, the petitioner had traveled to China multiple times between 1924 and 1947, during which he could have made adequate arrangements for his children to come to the Philippines, especially before the Sino-Japanese War. The absence of a satisfactory explanation from the petitioner regarding his failure to bring his children was critical in the Court's decision.
Res Judicata Principle
The Court referenced its previous ruling that established that Go Bon Lee had not made significant efforts to brin
...continue readingCase Syllabus (G.R. No. 224097)
Case Background
- The case involves Wilfredo Go Bon Lee (the petitioner) seeking Philippine citizenship through a petition filed in the Court of First Instance of Cebu.
- On August 15, 1951, the Solicitor General filed a petition to cancel Go Bon Lee’s previously granted naturalization certificate, citing failure to enroll his minor children in any recognized educational institution in the Philippines.
- The order denying the Solicitor General's petition was appealed, leading to a decision that revoked Go Bon Lee's certificate of naturalization.
Subsequent Petitions
- After the revocation decision became final, Go Bon Lee filed a new petition on June 23, 1961, attempting to rectify the educational enrollment issue.
- The City Fiscal of Cebu opposed this new petition, reiterating the ground that Go Bon Lee had not enrolled his minor children in recognized schools.
Court's Decision
- The lower court denied Go Bon Lee's petition, leading to the current appeal.
- The Supreme Court affirmed the lower court's decision, emphasizing that the petitioner failed to meet the naturalization requirements.
Petitioner’s Background
- Wilfredo Go Bon Lee was born on June 9, 1884, in Amoy, China, to Chinese parents and came to the Philippines on December 17, 1919.
- He was married in 1917 to Sy Hong in A