Republic vs. Cesar Guy
G.R. No. 41399

FACTS: August 18,1956, Cesar Guy filed with the Court of First Instance a petition to be admitted as a citizen of the Philippines. The petition was given due course and after hearing, the Court issued order granting the application for citizenship of Cesar Guy. December 22, 1959, Two years later the trial court issued order allowing Cesar Guy to take his oath of allegiance as citizen of the Philippines, he took his oath the same day and then issued Certificate of Naturalization No. 27.
September 23,1964, the Solicitor General filed petition with the court for the cancellation of the Certificate of Naturalization issued to Cesar Guy on the ground that the same was obtained fraudulently or illegally.
--June 7, 1957 Cesar Guy filed with Bureau of Forestry a sworn application for the issuance of an ordinary timber license where he stated that he was a Filipino citizen though he was not.
--He was found guilty of the crimes that demonstrating an utter lack of good moral character and has ceased to possess the qualifications to be naturalized citizen of the Philippines.
Cesar Guy claimed that he acted in good faith in applying for an ordinary timber license believing that he is already a citizen of the Philippines because of the favorable decision on his naturalization case.
May 28, 1974, the trial court ordered the cancellation of Certificate of Naturalization No. 27, previously issued to Cesar Guy, “in view of his conducts which resulted in his conviction for the crimes of perjury and rape, acts clearly indicative of his lack of one the important qualifications, that is good moral character”.

ISSUE: Whether or not the convictions of the appellant for certain crimes he committed after the probationary period is a valid ground for the cancellation of his Certificate of Naturalization.

HOLDING: Yes, because the fact that his convictions for the said crime were made after the 2 years probationary period and after the appellant had already been granted his citizenship unlike final decisions in actions and other proceedings in court, a decision or order granting citizenship to the applicant does not really become executory, and a naturalization proceeding not being a judicial adversary proceeding, the decision rendered therein is not res judicata, the certificate of naturalization may be cancelled upon grounds or conditions subsequent to the granting of the certificate of naturalization. 
The crime of perjury and rape undisputedly involves moral turpitude. Person convicted of said offense cannot be said to be possessed of good moral character, an indispensable requirement for one applying for Philippine citizenship. Hence, having been able to obtain Philippine citizenship despite this misconduct, rendered his acquisition thereof fraudulent and illegal. Consequently, the certificate of naturalization issued to him under these circumstances was properly cancelled by the court.
The judgment appealed was affirmed.

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