G.R. No. L-35947, 20 October 1992 [Citizenship; Naturalization; Grounds for Denaturalization]
FACTS:
William Li Yao was naturalized as a Filipino citizen pursuant to the C.A. No. 473 and R.A. No. 530. 15 years later, the Solicitor General filed a petition to cancel his naturalization because he obtained such through fraud and tax evasion. Li Yao denied the allegations.
ISSUE:
Whether or not the cancellation of Li Yao's naturalization is valid.
RULING:
Yes. The cancellation of the naturalization certificate of Li Yao was on the ground that it was "fraudulently and illegally obtained" based on the Section 18(a) of CA 473, also known as the Revised Naturalization Law.
A certificate of naturalization may be cancelled if it is subsequently discovered that the applicant obtained it by misleading the court upon any material fact. Law and jurisprudence even authorize the cancellation of a certificate of naturalization upon ground had conditions arising subsequent to the granting of the certificate. Moreover, a naturalization proceeding is not a judicial adversary proceeding, the decision rendered therein, not constituting 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.
