Case Summary (G.R. No. 35947)
Background of Naturalization
On October 25, 1950, the court declared Li Yao a naturalized Filipino citizen, contingent upon compliance with Republic Act No. 530. This act included a two-year probation period during which certain requirements needed to be fulfilled. Following his application, Li Yao was granted the opportunity to take his oath of allegiance on November 20, 1952, after the court confirmed his compliance with the stipulated requirements.
Motion for Cancellation
On January 5, 1968, after a period of approximately fifteen years, the Republic of the Philippines filed a motion to cancel Li Yao's certificate of naturalization, claiming it had been fraudulently obtained. The grounds for this motion included allegations of his moral character and conduct, including failing to be truthful about his identity, evading taxes, engaging in illicit relationships, and employing dummies to acquire property contrary to legal provisions.
Court's Decision on Cancellation
On July 22, 1971, the lower court granted the motion to cancel the naturalization certificate, specifically citing Li Yao's underdeclaration of income tax as grounds, thereby neglecting to address the other claims made by the Solicitor General. Li Yao opposed this order and subsequently filed a motion for reconsideration, which was denied on December 29, 1971.
Appeal and Implications
Li Yao appealed the decision on January 7, 1972, but passed away before the case was resolved. Nevertheless, the appeal retained relevance due to its implications for his surviving family members. The central issue revolved around the validity of the cancellation of his certificate of naturalization.
Legal Basis for Cancellation
The appeal was determined to be without merit. The cancellation was grounded in Section 18(a) of Commonwealth Act No. 473, which allows for cancellation if a certificate is acquired fraudulently or illegally. The court reiterated that naturalization can be revoked for misleading the court regarding material facts, and that subsequent findings of illegal conduct could warrant cancellation even post-naturalization.
Findings of Moral Character
The court underscored that the determination of good moral character is crucial to obtaining and retaining citizenship, as demonstrated in prior jurisprudence. Li Yao's alleged failure to adhere to tax laws, coupled with the implications of his conduct, were significant in undermining his moral character, rendering him ineligible for citizenship.
Importance of Compliance with Naturalization Law
The ruling emphasized that ci
...continue readingCase Syllabus (G.R. No. 35947)
Case Background
- The case arises from an appeal against the order of the Court of First Instance of Manila which canceled the naturalization certificate of William Li Yao.
- The initial petition for naturalization was filed by William Li Yao, a Chinese national, on June 3, 1949, which was granted on October 25, 1950, under the condition that certain requirements were fulfilled within a two-year probationary period.
- William Li Yao was allowed to take his oath of allegiance and was issued a certificate of naturalization on November 20, 1952.
Grounds for Cancellation
- On January 5, 1968, the Solicitor General filed a motion to cancel Li Yao's certificate of naturalization, alleging that it was fraudulently obtained based on several grounds:
- Lack of good moral character due to illicit relationships and fathering illegitimate children.
- Misrepresentation of his identity when contracting marriage.
- Evasion of taxes through underdeclaration of income.
- Violations of the Constitution and Anti-Dummy laws.
- Misrepresentation in legal documents regarding his illegitimate child.
Court Proceedings
- William Li Yao contested the cancellation motion but the lower court focused on the tax-related allegations.
- On July 22, 1971,