Republic v. Lee Bon Ui
REITERATIONFacts
The Antecedents: Lee Bon Ui alias Vicente Lee Beon Ui was granted his application for admission as a Filipino citizen by the Court of First Instance of Manila on June 24, 1960. On June 26, 1962, he filed a motion for execution of the decision, praying to take his oath as a Filipino citizen. Procedural History: The Government, through the Solicitor General, opposed the oath-taking, alleging that Lee Bon Ui had entered into a contract with the Philippine Tobacco Administration (PTA) to buy tobacco worth P2,486,600.00, failed to pay P2,467,157.60 for tobacco he withdrew and sold, and that this conduct demonstrated he was not of good moral character and had acted prejudicially to the nation's interests. The respondent-appellee countered that his non-payment was justified by damages suffered due to PTA's breach of contract. The Government filed a Supplemental Opposition and Memorandum, reiterating grounds of lack of good moral character, irreproachable conduct, acts prejudicial to the nation, insincerity, and lack of qualifications. The appellee replied that the decision granting citizenship was final and executory, that there was an amicable settlement with PTA, and that his children's enrollment in Chinese schools was not a ground for denial. The trial court denied the opposition and allowed the oath-taking. Lee Bon Ui took his oath on February 9, 1963. Subsequently, on September 26, 1968, the Solicitor General filed a motion to cancel the Certificate of Naturalization, alleging it was null and void due to fraudulent and/or illegal procurement. The Petition: The Government appealed the order denying its motion to cancel the Certificate of Naturalization.
Issue(s)
Whether the trial court erred in ruling that the respondent's lack of intention to pay his obligation to the Philippine Tobacco Administration cannot be inferred from mere inability or failure to pay. Whether the trial court erred in admitting in evidence a document not properly authenticated, purporting to be a permission to renounce Chinese nationality. Whether the trial court erred in denying the Government's motion to cancel the Certificate of Naturalization issued to the respondent Lee Bon Ui.
Ruling
The Supreme Court reversed the order of the trial court, declared the oath of allegiance and the certificate of naturalization null and void, and directed the appellee to surrender the certificate.
Ratio Decidendi
On the issue of the respondent's lack of intention to pay his obligation to the Philippine Tobacco Administration: The Court found merit in the government's assignment of error. It noted that during the two-year period after the decision granting citizenship and before the oath-taking, the appellee incurred a substantial indebtedness with the PTA. The government's opposition was based on his failure to pay for tobacco withdrawn and sold, which demonstrated a lack of good moral character and irreproachable conduct. The Court observed that the appellee induced PTA officials into an amicable settlement, reducing his debt, which led to the withdrawal of the government's opposition and his subsequent oath-taking. However, he paid only a portion of the reduced liability and failed to pay the balance, arguing that any subsequent non-payment was beyond inquiry. The Court found this stand untenable, emphasizing that a naturalization proceeding is not an adversary proceeding and its decision is not res judicata regarding grounds for cancellation due to illegal or fraudulent procurement. The two-year period is a test of fitness, and failure to abide by obligations undermines the State's guarantee of compliance with laws. The Court concluded that the compromise agreement was a scheme to remove an obstacle to oath-taking, and the appellee's subsequent refusal to comply with the compromise agreement, coupled with his defense, revealed insincerity and deceit amounting to fraud. On the issue of admitting an unauthenticated document: The Court found it unnecessary to pass upon this ground, as it had already determined that the certificate of naturalization was obtained through fraud based on the appellee's conduct regarding his PTA obligations. The Court stated that misleading both the Government and the lower court to be allowed to take an oath as a citizen is an act of fraud. On the issue of denying the Government's motion to cancel the Certificate of Naturalization: The Court ruled that the trial court erred in denying the motion. It reiterated that a naturalization certificate can be cancelled if it is discovered that the applicant obtained it by misleading the court on any material fact. The Court found that the appellee's actions, particularly his failure to fulfill the terms of the compromise agreement after using it to facilitate his oath-taking, constituted fraud. The Court emphasized that the two-year period after the grant of naturalization serves as an actual test of the petitioner's fitness, and failure to meet obligations during this period, or even after, can be grounds for cancellation. The Court concluded that the appellee's conduct demonstrated insincerity and deceit, making the certificate of naturalization null and void.
Main Doctrine
A certificate of naturalization may be cancelled if it is discovered subsequently that the applicant therefor obtained it by misleading the court upon any material fact, as naturalization proceedings are not adversary and the decision rendered therein is not res judicata as to any matter that would support a judgment cancelling a certificate of naturalization on the ground of illegal or fraudulent procurement thereof. The two-year intervening period after a decision granting naturalization is an actual test of fitness, and failure therein means the State has no guarantee the petitioner will abide by the laws of the adopted country.