Republic vs.

Liao [October 20, 1992]

Appeal from the order of CO! of "a#ila
Facts:
William Li Yao, a Chinese national, fled for a petition for naturalization on June 3, 1949!n the
decision of the court it "as held that he possesses all the #ualifcations necessar$ to %ecome a
naturalized Filipino %ut the decision shall not %ecome e&ecutor$ until after ' $ears from its
promul(ation "hen the court is satisfed that durin( the inter)enin( period, the applicant has *1+
not left the ,hilippines- *'+ has dedicated himself to a la"ful callin( or profession- *3+ has not
%een con)icted of an$ o.ense or )iolation of /o)ernment promul(ated rules- or *4+ committed
an$ act pre0udicial to the interest of the nation or contrar$ to an$ /o)ernment announced
policies
1o)em%er '2, 193' 4 pra$ed for the e&ecution of the decision of the court and the court
allo"ed him to ta5e his oath of alle(iance as Filipino
Januar$ 3, 1967 4 8olicitor /eneral fled a motion to cancel the certifcate of naturalization of
Yao on the (round that it "as fraudulentl$ and ille(all$ o%tained
Lo"er court cancelled his certifcate of naturalization on the %asis that he e)aded pa$ment of
ta&es due to the (o)ernment %$ under declaration of his income Yao fled a motion for
reconsideration %ut it "as denied
Januar$ 9, 199' :fled a notice of appeal to the 8C ;fter %oth parties fled their %riefs Li Yao
died %ut the case is not moot %ecause its disposition "ould ha)e (ra)e implications for the "ife
and children of Li Yao
!ssue: W<1 the cancellation of the certifcate of naturalization of Li Yao made %$ the (o)ernment
throu(h the o=ce of the 8olicitor /eneral is )alid
>eld: Yes
?atio:
@ased on section 17*a+ of Com ;ct no 493 5no"n as the ?e)ised 1aturalization ;ct, "hich
pro)ides that a naturalization certifcate ma$ %e cancelled if it is sho"n that said naturalization
certifcate "as o%tained fraudulentl$ or ille(all$
; naturalization proceedin( is not a 0udicial ad)ersar$ proceedin(, the decision rendered
therein, not constitutin( res 0udicata as to an$ matter that "ould support a 0ud(ment cancellin( a
certifcate of naturalization on the (round of ille(al or fraudulent procurement thereof
Lim An( Yu )s ?epu%lic 4 concealment of applicantBs income to e)ade pa$ment of la"ful ta&es
sho"s that his moral character is not irreproacha%le, thus dis#ualif$in( him for naturalization
A)en if the Li Yao paid his ta& lia%ilit$ )ia the ta& amnest$ pro(ram its le(al e.ect "ould merel$
remo)e an$ ci)il, criminal or administrati)e lia%ilit$ on the part of the ta&pa$er, onl$ insofar as
his ta& case is concerned Ca& amnest$ does not ha)e the e.ect of o%literatin( his lac5 of (ood
moral character and irreproacha%le conduct "hich are (rounds for denaturalization
1aturalization la"s should %e ri(idl$ enforced in fa)or of the (o)ernment and a(ainst the
applicant When the applicant failed to meet the #ualifcations re#uired for naturalization, the
latter is not entitled to Filipino citizens