Go vs. Republic GR 202809

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Dennis L. Go vs.

Republic of the Philippines

G.R. No. 202809, July 2, 2014

FACTS

Petitioner filed a petition for naturalization under Commonwealth Act No. 473, the Revised
Naturalization Law. Aside from his presentation of all other requirements, petitioner presented, as
witnesses, Dr. Anlacan, Dr. Tordesillas, Silivino Ong, Teresita Go, and Juan Go.

Dr. Anlacan testified that based on the psychiatric examination he conducted on petitioner, he
had no psychiatric abnormality at the time of the test. Dr. Tordesillas, on the other hand, reported that
petitioner's medical examination results were normal. Ong, a friend of petitioner's family, said that he
had known petitioner since childhood through his association with the family in times of celebration.
Teresita described him as a peace-loving person who participated in activities sponsored by his school
and the barangay. Lastly, Juan, a businessman by profession, also claimed that he knew petitioner
personally.

The RTC rendered a discussion granting the petition for naturalization ruling that the petitioner
possessed the qualification set forth by law. But the CA reversed and set aside said decision. Hence, this
petition.

ISSUE

Whether or not Go's petition for naturalization should be granted.

RULING

No. Jurisprudence dictates that in judicial naturalization, the application must show substantial
and formal compliance with C.A. No. 473. In other words, an applicant must comply with the
jurisdictional requirements, establish his or her possession of the qualifications and none of the
disqualifications enumerated under the law, and present at least two character witnesses to support his
allegations.

In Ong v. Republic of the Philippines, the Court listed the requirements for character witnesses,
namely:

1. That they are citizens of the Philippines


2. That they are credible persons
3. That they personally know the petitioner
4. That they personally know him to be a resident of the Philippines for the period of time required
by law
5. That they personally know him to be a person of good repute
6. That they personally know him to be morally irreproachable
7. That he has, in their opinion, all the qualifications necessary to become a citizen of the
Philippines, and
8. That he "is not in any way disqualified under the provisions" of the Naturalization Law.
The records of the case show that the joint affidavits executed by petitioner's witnesses did not establish
their own qualification to stand as such in a naturalization proceeding. In turn, petitioner did not present
evidence proving that the persons he presented were credible. In other words of the CA, "he did not
prove that his witnesses had good standing in the community, known to be honest and upright, reputed
to be trustworthy and reliable, and that their word may be taken at face value, as a good warranty of the
worthiness of the petitioner".

Furthermore, the background checks done on petitioner yielded negative results due to the
uncooperative behavior of the members of this household. In fact, petitioner himself disobliged when
asked for an interview by BOI agents. To the court, this is a display of insincerity to embrace Filipino
customs, traditions and ideals.

Finally, it is noteworthy that petitioner's failure to state his former residence in the petition was
fatal to his application or naturalization. Indeed, this omission had deprived the trial court of jurisdiction
to hear and decide the case.

Hence, the petition for naturalization is dismissed without prejudice.

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