**Facts:**
1. **December 3, 2007:** Go Pei Hung, a British subject and Hong Kong resident, filed a Petition for Naturalization in the Regional Trial Court (RTC) of Manila, docketed as Naturalization Case No. 07-118391.
2. **July 21, 2010:** The RTC of Manila issued a Decision granting Go Pei Hung’s petition, finding that he met all the qualifications under Section 2 of Commonwealth Act No. 473 (CA 473).
3. **RTC’s Decision Highlights:**
– Go Pei Hung, born in 1961, presented evidence of continuous residency in the Philippines since 1989.
– Submitted testimonies and evidence of good moral character and a lucrative profession.
– RTC scheduled a two-year review hearing as mandated under Republic Act 530.
4. **Petitioner’s Appeal:** The Republic, through the Office of the Solicitor General (OSG), appealed the RTC decision to the Court of Appeals (CA), raising four main errors:
– Failure to file a Declaration of Intention.
– Failure to attach a Certificate of Arrival.
– Failure to prove a lucrative trade, profession, or occupation.
– Failure to present two credible witnesses.
5. **February 28, 2014:** The CA affirmed the RTC’s Decision, dismissing the appeal.
6. **June 5, 2014:** The CA denied the Republic’s Motion for Reconsideration.
7. **Supreme Court Appeal:** The Republic filed a Petition for Review on Certiorari with the Supreme Court, arguing procedural and substantive errors in Go Pei Hung’s application.
**Issues:**
1. **Non-Compliance with Declaration of Intention:** Whether Go Pei Hung’s failure to file the Declaration of Intention disqualified him from naturalization.
2. **Certificate of Arrival:** Whether the lack of a Certificate of Arrival invalidated Go Pei Hung’s petition for naturalization.
3. **Lucrative Trade/Profession:** Whether Go Pei Hung sufficiently demonstrated his engagement in a lucrative trade, profession, or occupation.
4. **Credibility of Witnesses:** Whether the character witnesses presented were credible under the requirements of Section 7 of CA 473.
**Court’s Decision:**
1. **Declaration of Intention:** The Supreme Court ruled that Go Pei Hung was not exempt from filing a Declaration of Intention. The evidence showed he only became a permanent resident in 1989, not meeting the required continuous residence of 30 years.
2. **Certificate of Arrival:** The Supreme Court emphasized the mandatory nature of attaching the Certificate of Arrival to ensure lawful entry. Go Pei Hung’s failure to attach this document rendered his petition null and void.
3. **Lucrative Trade/Profession:** The Court did not address this issue in-depth, as the petition already failed procedural grounds.
4. **Credibility of Witnesses:** The Court also did not delve extensively into this issue due to the procedural failures already determining the case.
**Doctrine:**
– **Mandatory Compliance:** Full and complete compliance with the procedural and substantive requirements of the naturalization law (CA 473) is mandatory. The absence of any requirement, such as the Declaration of Intention or Certificate of Arrival, is fatal to the application.
– **Strict Construction:** Naturalization laws are to be strictly construed in favor of the state and against the applicant to protect national interest.
**Class Notes:**
– **Naturalization Requirements (Commonwealth Act No. 473):**
– **Section 2:** Applicants must meet qualifications such as age, continuous residence, good moral character, lucrative profession, language proficiency, and proper education for minor children.
– **Section 5:** Requires a Declaration of Intention to be filed with the OSG one year prior to the petition.
– **Section 7:** Petition must include a Certificate of Arrival and be supported by affidavits from credible witnesses.
– **Section 6:** Exemptions from the Declaration include being born in the Philippines and residents for over 30 years.
– **Republic Act 530:** Decision on naturalization remains not final for two years pending compliance review.
– **Key Case References:**
– **Republic v. Hong:** Reinforces the necessity of full compliance with the naturalization law’s requirements.
– **Republic v. Judge De la Rosa:** Establishes failure to attach a Certificate of Arrival as a substantive error voiding the petition.
**Historical Background:**
– **Naturalization Law’s Context:** Enacted in 1939 to control and manage the process of foreign nationals acquiring Philippine citizenship, ensuring that applicants have integrated well and comply fully with legal norms.
– **Post-War Legislation:** Post-World War II, naturalization laws were rigorously enforced to stabilize and monitor the resident alien population amid security concerns.
The Supreme Court’s strict interpretation in this case underscores the enduring focus on stringent adherence to statutory requirements in naturalization proceedings, reflecting broader security and national interest considerations.
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