Wednesday, May 12, 2021

Case Digest_PALER, Meg Dianne C._Petition for admission to Philippine citizenship, Cezar Luchayco, also known as Cesar Lu, petitioner-appellee, v. Republic of the Philippines, G.R. NO. L-25814, JULY 30, 1969

 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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