Lee v. Republic
REITERATIONFacts
The Antecedents: Jimmy Lee, a Chinese national, filed a petition for naturalization with the Court of First Instance of Iloilo. The opposition was filed by the Republic of the Philippines on the general ground that the petitioner did not possess all the requisite qualifications for naturalization. Procedural History: The Court of First Instance of Iloilo rendered judgment admitting the petitioner to Philippine citizenship. However, the Office of the Solicitor General filed a motion to annul the proceedings, asserting that the one-year jurisdictional requirement for filing a declaration of intention had not been met. The lower court denied this motion, leading to the present appeal. The Petition: The appeal challenges the denial of the motion to annul the naturalization proceedings. The core issue is whether the petitioner's declaration of intention was validly filed within the statutory one-year period prior to the filing of the naturalization petition, considering that the required filing fee was paid significantly later than the initial submission of the declaration.
Issue(s)
Whether the filing of a Declaration of Intention is considered legally effective only upon the payment of the required filing fee, thereby determining the start of the mandatory one-year period before a petition for naturalization can be filed.
Ruling
The Supreme Court set aside the order appealed from and declared all proceedings leading to the rendition of the judgment granting the petitioner's application for citizenship null and void.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Declaration of Intention (DOI) was not validly filed until the payment of the P10.00 fee on May 23, 1956. Under Section 5 of the Revised Naturalization Law, an applicant must file a declaration of intention with the Office of the Solicitor General (OSG) at least one year before filing the petition in court. Section 21 of the same law authorizes the Secretary of Justice and the Solicitor General to issue regulations for its enforcement, including the imposition of filing fees. Applying the principle in pari materia from Lazaro vs. Endencia (57 Phil. 552), the Court held that just as an appeal is not perfected without the payment of docket fees, a declaration is not 'filed' without the corresponding fee. The Court concluded that the October 23, 1953, mailing had no legal value until the fee was remitted in 1956. Because the petition for naturalization was filed only five and a half months after the fee payment, it failed to meet the one-year jurisdictional requirement. Since naturalization is a privilege and not a right, the law must be strictly complied with; therefore, the CFI lacked jurisdiction, and its judgment was a nullity.
Main Doctrine
The payment of the required filing fee for the declaration of intention is a mandatory requirement that must be complied with to give the declaration legal effect and to satisfy the one-year jurisdictional period before filing a petition for naturalization.