Case Name Republic of the Philippines VS Huang Te Fu A.K.A.

Robert Uy

Topic Citizenship: Naturalization proceeding

Case No/Date . G.R. No. 200983, March 18, 2015

Ponente Del Castillo, J.

Doctrine An applicant for naturalization must show full and complete compliance
with the requirements of naturalization law or Commonwealth Act No. 473;
otherwise, his petition for naturalization will be denied.

Relevant Facts

•March 19, 2004: Huang Te Fu, also known as Robert Uy, filed a sworn Declaration of Intent to
Become a Citizen of the Philippines with the Office of Solicitor General on March 19, 2004. Then, he
filed a Petition for Naturalization with the Regional Trial Court stating, among others:

◊ His place of residency

◊ His trade or profession

◊ He was born in Taiwan

◊ His Chinese citizenship

◊ He was married to a Filipino woman named Irene D. Chan whom he had two children with

◊ the date when he arrived to the Philippines

◊ He has resided in the Philippines for twenty-three years during which he attained his
primary education until finishing college

◊ He is of good moral character

•September 2007, the Court found Huang Te Fu to have fulfilled all the required qualifications and
thereby granted his petition for admission as a citizen of the Philippines. However a petition was filed
to the Court of Appeals, revealing contrary facts from the ones given by Huang Te Fe that can deny
his admission. Some of the facts revealed that Huang Te Fu did not really own any real estate in the
Philippines and the contracts he and his wife signed to purchase a land in Antipolo misrepresented
him as a Filipino. Also, he could not cite in verbatim principles in the Philippine Constitution which he
claimed to believe in. But, the Court decided that just because he could not cite them in vervatim,
does not mean that he does not believe in them. Finding that Huang Te Fe is of no fault, the court
denied the petition and affirmed his Naturalization. The petitioner moved for reconsideration but the
decision stood. Thus, the petitioner filed to the Supreme Court.

Issue:

Whether or not Huang Te Fu is entitled to be admitted as a citizen of the Philippines through

naturalization.

Ruling:

No, under Section 2 of Commomwealth Act 473 or the Revised Naturalization Law, any person
must meet the qualifications to acquire citizenship in the Philippines by naturalization. The Ponente
in the case of Republic vs Huang held that naturalization laws should be rigidly enforced and strictly
construed in favour of the government and against the applicant. Thus, as Huang Te Fu did not fully
and complately complied with the requirements of the said law, his application was denied.

Ruling

GRANTED. Regional Trial Court and Court of Appeals’ decisions are reversed.

Notes:

•Comparison with Republic vs Ong:

◊ This case deals on Commomwealth Act 473, Ong failed to prove that he possesses the
qualification of a known lucrative trade provided in Section 2, fourth paragraph of the Revised
Naturalization Law.