That's not really correct.
You can use days spent in Canada before you became a PR towards your citizenship count. So it's entirely possible to apply for citizenship before you have been a PR for 3 years.
Well correct, also.. as it adds to what I stated.. it can be 2 years of permanent residency + 2 years of temporary residency as those are counted 2 to 1.
the question here is about Basic residency physical presence obligations for the Citizenship.. in Papadogiorgakis case he had only 79 days of physical presence AFAIK
........ It has long been established in the Canadian citizenship field, that physical presence is not essential provided that the landed immigrant has established and maintained throughout the three year period in question, a "pied-...-terre" in Canada and has the clear intention to live in this country. Applicants who had in mind and fact, settled into, maintained or centralized their ordinary mode of living in Canada could be determined to have fulfilled the citizenship residence requirements with as little as 79 days of physical presence in Canada during the relevant four year period: Re Papadogiorgakis, [1978] 2 F.C. 208 (T.D.).
Indeed, this liberal application of the Citizenship Act is often followed by citizenship judge's who opt for a flexible interpretation of the Act to account for justified absences from Canada. In order to ascertain whether an applicant under this approach, has centralized his or her mode of existence in Canada, a number of issues are examined by the judge, including:
Was the individual physically present in Canada for a long period prior to recent absences which occurred immediately before the application for citizenship;
Where are the applicant's immediate family and dependants resident;
Does the pattern of physical presence in Canada indicate a returning home or merely visiting the country;
What is the extent of the physical absences;
Is the physical absence caused by a clearly temporary situation such as employment as a missionary abroad, following a course of study abroad as a student, accepting temporary employment abroad, accompanying a spouse who has accepted temporary employment abroad;
What is the quality of the connection with Canada: is it more substantial than that which exists with any other country.
This latter issue is usually examined from the perspective of the indicia of applicant's ties to Canada. To avail the benefits of this approach, applicants are encouraged to maintain Canadian bank accounts, magazine subscriptions, Medicare cards, lodgings, furniture, driver licenses, bank cards, and enroll their children in Canadian schools. ...
more here:
http://findarticles.com/p/articles/mi_hb155/is_1_16/ai_n28811598/
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