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ONG CHIA v. REPUBLIC

FACTS:

Ong Chia, a Chinese national, migrated to the Philippines as a nine-year-old boy in 1932. He resided in the country, worked, established his own business, and married a Filipina. In 1989, at the age of 66, Ong Chia filed a petition to obtain Filipino citizenship under the Revised Naturalization Law. The prosecutor expressed admiration for Ong Chia's testimony during the hearings and believed that he deserved to become a citizen. The trial court granted Ong Chia's petition and admitted him as a Filipino citizen. Nevertheless, the Office of the Solicitor General challenged the decision, contending that Ong Chia did not comply with the requirements of the law. Specifically, they argued that he failed to provide all his names, former places of residence, did not conduct himself properly and irreproachably, lacked a recognized lucrative trade or occupation, and failed to present adequate documentary evidence to substantiate his petition. Subsequently, the Court of Appeals reversed the trial court's ruling, denying Ong Chia's application for naturalization due to his failure to meet the legal prerequisites.

ISSUES:

  1. Whether the Court of Appeals gravely abused its discretion in ruling that the appellate court can deny an application for Philippine citizenship based on documents not presented before the trial court and not forming part of the records of the case.

  2. Whether the finding of the Court of Appeals that the petitioner has been known by some other name not stated in his petition is supported by evidence on record.

  3. Whether the petitioner stated in his petition and its annexes his present and former places of residence.

  4. Whether the finding of the Court of Appeals that the petitioner failed to conduct himself in a proper and irreproachable manner is supported by evidence on record.

RULING:

  1. No. The Supreme Court ruled that the contention has no merit. Rule 143 of the Rules of Court provides that naturalization proceedings are an exception to the rule on the formal offer of evidence.

  2. Yes. The Court of Appeals' finding that petitioner had been known by another name ("Loreto Chia Ong") that was not stated in his petition is supported by evidence, specifically the petitioner's previous application under Letter of Instruction No. 270.

  3. No. The Supreme Court found that petitioner failed to disclose his former place of residence at "J.M. Basa St., Iloilo" in his petition, which is a mandatory requirement under Section 7 of the Revised Naturalization Law (C.A. No. 473).

  4. Yes. The Court held that petitioner's long cohabitation with his wife without the benefit of marriage indicated that he did not conduct himself in a proper and irreproachable manner as required for naturalization.

PRINCIPLES:

  • Rule 143 of the Rules of Court The rules of court do not apply in naturalization proceedings except by analogy or in a suppletory character.

  • Strict Construction of Naturalization Laws Naturalization laws are to be rigidly enforced and strictly construed in favor of the government and against the applicant.

  • Mandatory Petition Requirements under C.A. No. 473, §7 The petition for naturalization must state all present and former places of residence.

  • Proper and Irreproachable Conduct Applicants must conduct themselves in a proper and irreproachable manner during their entire stay in the Philippines.

  • Consideration of Public Documents Public documents executed under oath are considered reliable unless their authenticity is satisfactorily disputed.