Go vs Republic

Issue: Was the petitioner able to prove that he has all qualifications and none of the disqualifications?

Ruling: No. Petitioner failed to prove that he has all the qualifications entitling him to the grant of Philippine citizenship.
The joint affidavits executed by petitioner’s witnesses did not establish their own qualification to stand as such in a
naturalization proceeding. Thus, petitioner did not present evidence proving that the persons he presented were
credible and he did not prove that his witnesses had good standing in the community, known to be honest and upright,
reputed to be trustworthy and reliable, and that their word may be taken at face value, as a good warranty of the
worthiness of petitioner. There was therefore no indication that they were persons whose qualifications were at par
with the requirements of the law on naturalization. Thus, petitioner failed to prove that he has all the qualifications
entitling him to the grant of Philippine citizenship.

Issue: Is failure to state his former residence in his petition fatal?

Ruling: Yes, petitioner’s failure to state his former residence in the petition was fatal to his application for
naturalization. The omission had deprived the trial court of jurisdiction to hear and decide the case. The inclusion of
present and former places of residence in the petition is a jurisdictional requirement.

FYI: Under the present laws, the process of naturalization can be judicial or administrative. Judicially, C.A. No. 473
provides that after hearing the petition for citizenship and receipt of evidence showing that the petitioner has all the
qualifications and none of the disqualifications required by law, the competent court may order the issuance of the
proper naturalization certificate and the registration thereof in the proper civil registry. On the other hand, Republic Act
(R.A.) No. 9139 provides that aliens born and residing in the Philippines may be granted Philippine citizenship by
administrative proceeding by filing a petition for citizenship with the Special Committee, which, in view of the facts
before it, may approve the petition and issue a certificate of naturalization.

Jurisprudence dictates that in judicial naturalization, the application must show substantial and formal compliance with
C.A. No. 473. An applicant must comply with the jurisdictional requirements, establish his or her possession of the
qualifications and none of the disqualifications enumerated under the law, and present at least two (2) character
witnesses to support his allegations.

Kabataan PL vs Comelec

Issue: Whether or not the penalty of deactivation under RA 10367 is an unconstitutional substantive requirement in
the exercise of the right of suffrage?

Ruling: No. The penalty of deactivation, as well as the requirement of validation, neutrally applies to all voters. Thus,
petitioners' argument that the law creates artificial class of voters is more imagined than real. There is no favor accorded
to an "obedient group." If anything, non-compliance by the "disobedient" only rightfully results into prescribed
consequences. Surely, this is beyond the intended mantle of the equal protection of the laws, which only works "against
undue favor and individual or class privilege, as well as hostile discrimination or the oppression of inequality."s

In the first place, the biometrics validation requirement is not a "qualification" to the exercise of the right of suffrage,
but a mere aspect of the registration procedure, of which the State has the right to reasonably regulate.

Dano vs COmelec

Issue: Must physical presence be unbroken to establish a domicile by choice?

Ruling: No. Although physical presence, along with animus manendi et revertendi, is an essential requirement for the
acquisition of a domicile of choice, the law does not require that physical presence be unbroken.

In Japzon v. Comelec, the Court ruled that to be considered a resident of a municipality, the candidate is not required to
stay and never leave the place for a full one-year period prior to the date of the election. In Sabili v. Comelec, the Court
reiterated that the law does not require a candidate to be at home 24 hours a day 7 days a week to fulfill the residency
requirement.

Issue: Did petitioner had fail to prove compliance with the one-year residency requirement?

Ruling: No. In this case, instead of evaluating the probative value of the evidence presented by petitioner, COMELEC
abruptly concluded that she had failed to reestablish her domicile in Sevilla, simply because she was admittedly absent
from the municipality for four months. In Japzon v. Comelec, the Court ruled that to be considered a resident of a
municipality, the candidate is not required to stay and never leave the place for a full one-year period prior to the date
of the election. Petitioner sufficiently established that she had already reacquired her Philippine citizenship when she
started residing in Sevilla on 2 May 2012.

Considering that the only material issue before COMELEC was the completeness of the period of residence, it should not
have disregarded the following evidence showing specific acts performed by petitioner one year before the elections,
which clearly demonstrated her animus manendi et revertendi:

1. She made public her intention to run for the mayoralty position. In preparation for this aspiration, and in order
to qualify for the position, she went through the reacquisition process under Republic Act No. 9225.

2. She started to reside in her ancestral home, and even obtained a CTC, during the first quarter of 2012.

3. She applied for voter's registration in Sevilla.

4. She went back to the US to dispose of her properties located there.