Case Summary (G.R. No. 202809)
Notice, Publication, and Evidence Presentation
Pursuant to Section 9 of C.A. No. 473, the trial court clerk published notice in the Official Gazette and a newspaper for three consecutive weeks, posted notices, and scheduled hearings. Petitioner testified and presented five witnesses—a psychiatrist, a medical doctor, and three acquaintances—whose affidavits and live testimony purportedly established his health, moral character, social integration, and support.
OSG’s Initial and Subsequent Motions
The OSG initially offered no objection to petitioner’s evidence and requested submission on the petitioner’s proofs. It later moved to reopen the trial to admit an NBI report suggesting petitioner’s non‐compliance with the law. The RTC admitted both parties’ evidence but denied the OSG’s motion to reopen. After granting naturalization, the RTC likewise denied a second reconsideration motion seeking admission of a BOI background report.
RTC Decision and Grounds for Grant
On November 18, 2008, the RTC granted naturalization, finding petitioner met all qualifications and had no disqualifications under C.A. No. 473, including absence of criminal record, support for organized government, health, social mingling with Filipinos, language ability, and moral fitness. The court ordered petitioner to take the oath of allegiance under R.A. No. 530.
Court of Appeals Reversal
The CA reversed and set aside the RTC decision, dismissing the petition without prejudice. It held petitioner failed to prove the credibility of his character witnesses—specifically, their standing in the community, honesty, reliability, and their competence to vouch as required by jurisprudence.
Witness Credibility Requirements
Under C.A. No. 473 and Supreme Court precedents (Ong v. Republic; Cuaki Tan Si v. Republic; Lim Ching Tian v. Republic), at least two citizen witnesses must personally know the petitioner, attest to his residence, repute, moral irreproachability, and absence of statutory disqualifications. A “credible person” must be of good community standing, honest, reputable, reliable, and competent to insure the petitioner’s character.
Supreme Court’s Analysis on Credibility
The Supreme Court agreed that petitioner’s witnesses lacked proof of their own credibility. Their affidavits contained only general declarations of petitioner’s mingling and adherence to constitutional principles without specific acts or events. No evidence established the witnesses’ honesty, uprightness, or reliability. The negative inference from the NBI and BOI reports—stemming from uncooperativeness by petitioner’s household—further undermined his claimed social integration and sincerity.
Jurisdictional Defect: O
...continue readingCase Syllabus (G.R. No. 202809)
Facts
- On October 13, 2004, petitioner Dennis L. Go filed a petition for naturalization under Commonwealth Act No. 473 before the RTC of Manila, docketed as Naturalization Case No. 03-107591.
- Petitioner alleged:
- Born on May 7, 1982 in Manila to Chinese‐national parents, Felix and Emma Go;
- Aged, single Chinese national; continuous resident at No. 1308-1310 Oroquieta Street since birth;
- Educated entirely in Philippine schools, fluent in English and Tagalog;
- Believed in Philippine constitutional principles, of good moral character, non-opposed to organized government, not affiliated with anti-government associations;
- Never advocated violence or polygamy; never convicted of crimes involving moral turpitude; in good health and of sound mind;
- Not a citizen of a state at war with the Philippines; intended in good faith to renounce all foreign allegiances, reside continuously in the Philippines until naturalization;
- Claimed exemption from filing a Declaration of Intention under Section 5 of C.A. No. 473 for being born and educated in the Philippines.
- Notice of hearing was published in the Official Gazette and a general-circulation newspaper for three consecutive weeks and posted in the RTC, as required by Section 9 of C.A. No. 473.
- During trial, petitioner testified in support of his petition and offered documentary evidence. He presented five character witnesses: Dr. Joseph Anlacan, Dr. Edward C. Tordesillas, Silvino J. Ong, Teresita M. Go, and Juan C. Go.
- The Office of the Solicitor General (OSG) initially raised no objection to petitioner’s evidence and requested submission of the case for decision, but later moved to reopen trial to admit an NBI investigation report (November 23, 2006).
- Petitioner produced an NBI clearance and denied identity with the subject of the report; the RTC admitted both sides’ evidence in an October 24, 2008 order but denied the OSG’s motion to reopen the trial.
Procedural History
- November 18, 2008: RTC Branch 45, Manila granted petitioner’s naturalization petition, finding he possessed all statutory qualifications and no disqualifications.
- The OSG filed a