Chia v. Republic
G.R. No. 127240, March 27, 2000

Facts: 

Petitioner Ong Chia was born in Amoy, China. In 1932, as a nine-year old boy, he arrived at the port of Manila and since then, has stayed in the Philippines where he found employment and eventually started his own business, married a Filipina, with whom he had four children. In 1989, at the age of 66, he filed a verified petition to be admitted as a Filipino citizen under C.A. No. 473, otherwise known as the Revised Naturalization Law, as amended. 

During the hearings, petitioner presented himself and three witnesses. The prosecutor was so impressed with the testimony of petitioner that he did not present any evidence. Accordingly, the trial court granted the petition and admitted petitioner to Philippine citizenship.

The State, however, through the Office of the Solicitor General appealed to the CA. It alleged that petitioner: (1) failed to state his other name "Loreto Chia Ong" in his petition; (2) failed to state his former place of residence; (3) failed to conduct himself in a proper and irreproachable manner during his entire stay in the Philippines, (4) has no known lucrative trade or occupation and his previous incomes have been insufficient or misdeclared, and (5) failed to support his petition with the appropriate documentary evidence. 

The CA reversed the trial court's decision and denied petitioner’s application for naturalization. It ruled that due to the importance of naturalization cases, the State is not precluded from raising questions not presented in the lower court and brought up for the first time on appeal.

Petitioner went to the Supreme Court, contending that the CA erred in considering the documents which had merely been annexed by the State to its appellant’s brief. According to petitioner, not  having  been  presented  and  formally  offered  as  evidence  during  the  trial,  they  are  mere "scraps of paper” devoid of any evidentiary value.

Issue: 

Whether or not the documents annexed by the State to its appelant’s brief without having been presented and formally offered as evidence under Rule 132, Section 34 of the Revised Rules on Evidence justified the reversal of of the trial court’s decision.


Held: 

Yes.

Rule 1, Sec. 4 of the Rules of Court which provides that —

These rules shall not apply to land registration, cadastral and election cases, naturalization and insolvency proceedings, and other cases not herein provided for, except by analogy or in a suppletory character and whenever practicable and convenient. 

Prescinding from the above, the rule on formal offer of evidence (Rule 132, §34) now being invoked by petitioner is clearly not applicable to the present case involving a petition for naturalization. The only instance when said rules may be applied by analogy or suppletorily in such cases is when it is "practicable and convenient." That is not the case here, since reliance upon the documents presented by the State for the first time on appeal, in fact, appears to be the more practical and convenient course of action considering that decisions in naturalization proceedings are not covered by the rule on res judicata. Consequently, a final favorable judgment does not preclude the State from later on moving for a revocation of the grant of naturalization on the basis of the same documents.

Petitioner cannot claim that he was deprived of the right to object to the authenticity of the documents submitted to the appellate court by the State. He could have included his objections, as he, in fact, did, in the brief he filed with the CA.