Doctrine:
The
grant of citizenship being a highly regarded privilege, there must be a
full and strict compliance with the requirements of the law before its benefits
can be enjoyed.
FACTS:
The Republic of the Philippines has challenged by
making an appeal regarding the the case against the grant of citizenship of Cezar Luchayco.
As far back as 1950, there
has been a rejection of the liberal construction of the above provision of the
Naturalization Law. It is easy to
understand why. As stated by us in Guy Co Chia v.
Republic: "This educational requirement is necessary not only to test the
sincerity of purpose of petitioner but to give him the proper perspective
regarding the ideals and principles of the citizenship he
seeks to embrace."
ISSUE:
Whether or not
Luchayco should be granted with Filipino citizenship based on his primary
education obtained in a Philippine school.
HELD:
There was no other testimony
regarding his compliance with the statutory requirement to justify his
exemption from filing a declaration of intention. 6 There was then a deficiency in proof, fatal in its
effects.
No evidence, however, aside from
applicant's own testimony, was presented to show that said school is not limited to a particular race or nationality. To our mind, his testimony, unsupported by other competent
evidence, is inadequate. The burden is on him to present such competent
evidence, he being the claimant of the exemption, and since he failed to do so,
he cannot be entitled to the exemption sought. And inasmuch as he filed no
declaration of intention, his petition for naturalization must be denied."
The Supreme Court
adhere to the basic concept that the grant of citizenship being
a highly regarded privilege, there must be a full and strict compliance with
the requirements of the law before its benefits can be
enjoyed. Under that fundamental postulate and with the lack of
evidence to substantiate his claim for exemption from filing a declaration of
intention, the petition in this case ought not to have been granted by the
lower court. With the view we take of this particular jurisdictional
objection, there is no need to inquire into the other grounds of opposition.
WHEREFORE, the decision of August 9, 1965
is reversed. With costs against petitioner.
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